On July 21, 2025, District Judge Paul A. Engelmayer (S.D.N.Y.) granted Defendants Teads, Inc., Teads SA, and Teads SARL’s (together, “Teads”) Motion to Dismiss Yieldmo, Inc.’s (“Yieldmo”) Amended Complaint alleging that Teads infringed four of its patents.
The patents at issue relate to methods that allow users to scroll through video advertisements frame by frame. The frame being viewed changes at a rate and in a direction corresponding to the user’s scrolling rate and direction. Yieldmo, Inc. v. Teads, Inc., No. 25 Civ. 737, at *3 (S.D.N.Y. July 21, 2025). Teads filed a Motion to Dismiss arguing that Yieldmo’s patents were invalid under 35 U.S.C. § 101. Id. at *1. The Court evaluated the claims at issue under the Mayo/Alice framework and agreed with Teads that the claims were directed to unpatentable subject matter. Id.
Under the first step of the Mayo/Alice test, the Court found that the patents were directed to the abstract idea of providing interactive advertising in response to consumer activity. Id. at *10. The Court then held that “tailoring advertisements to user activity . . . [is a] high-level concept [that] is not meaningfully concretized in the Patents” and thus an abstract idea. Id. at *11.
Under the second step of the Mayo/Alice test, the Court found that the claims did not contain an “inventive concept.” Id. at *15. Specifically, while Yieldmo argued that customizing advertisements based on scrolling activity and collecting engagement data was an “inventive concept,” the Court held that the claimed high level of functionality was achieved by “reciting no more than generic computer elements performing generic computer tasks [which] does not make an abstract idea patent-eligible.” Id. at *16. Additionally, Yieldmo argued that the claims solved a problem specific to the internet. However, the Court noted that “Yieldmo's Patents are merely the latest in a long line that propose to effectuate customized advertising. That undertaking does not present an Internet-specific challenge.” Id.
As such, the Court granted Tead’s Motion to Dismiss and found Yieldmo’s patents to be directed to an unpatentable abstract idea. Id. at *17.
The case is Yieldmo, Inc. v. Teads, Inc., No. 25 Civ. 737 (S.D.N.Y. July 21, 2025).
