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Application for Extension of Time to Answer Complaint is granted. 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Rodney Gilstrap.\n                               ______________________\n\n                ON PETITION FOR PANEL REHEARING AND\n                         REHEARING EN BANC\n                          ______________________\n             Before MOORE, Chief Judge, MAYER 1, LOURIE, DYK, PROST,\n              REYNA, TARANTO, CHEN, HUGHES, STOLL, CUNNINGHAM,\n                           and STARK, Circuit Judges. 2\n             PER CURIAM.\n                                     ORDER\n                 Core Scientific, Inc. filed a combined petition for panel\n             rehearing and rehearing en banc. The petition was referred\n             to the panel that issued the order, and thereafter the\n\n\n                 1   Circuit Judge Mayer participated only in the deci-\n             sion on the petition for panel rehearing.\n                 2   Circuit Judge Newman did not participate.\n\f             Case: 26-140\nCase 2:25-cv-00519-JRG-RSP Document:\n                             Document25126Page: 2 08/14/26\n                                            Filed   Filed: 08/13/2026\n                                                              Page 2 of 2 PageID #:\n                                     3826\n\n\n\n             2                                 IN RE CORE SCIENTIFIC, INC.\n\n\n\n\n             petition was referred to the circuit judges who are in regu-\n             lar active service.\n                 Upon consideration thereof,\n                 IT IS ORDERED THAT:\n                 The petition for panel rehearing is denied.\n                 The petition for rehearing en banc is denied.\n\n\n                                                          FOR THE COURT\n\n\n\n\n              August 13, 2026\n                  Date\n\f","ocr_status":2,"date_upload":"2026-08-28T11:34:15.822198-07:00","document_number":"126","attachment_number":null,"pacer_doc_id":"175015615024","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Notice (Other)","acms_document_guid":""}],"date_created":"2026-08-14T08:42:49.927614-07:00","date_modified":"2026-08-26T18:56:50.298617-07:00","date_filed":"2026-08-14","time_filed":"09:42:38","entry_number":126,"recap_sequence_number":"2026-08-14.001","pacer_sequence_number":352,"description":"USCA ORDER ON PETITION FOR PANEL REHEARING AND REHEARING EN BANC (mdj) (Entered: 08/14/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/471607665/","id":471607665,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/70244989/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/487016924/","id":487016924,"tags":[],"absolute_url":"/docket/70244989/124/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-07-21T11:09:57.298971-07:00","date_modified":"2026-07-21T11:09:57.315484-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"124","attachment_number":null,"pacer_doc_id":"175015549536","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Sur-Reply to Reply to Response to Motion","acms_document_guid":""}],"date_created":"2026-07-21T11:09:57.260270-07:00","date_modified":"2026-08-26T18:56:50.245445-07:00","date_filed":"2026-07-21","time_filed":"12:02:10","entry_number":124,"recap_sequence_number":"2026-07-21.001","pacer_sequence_number":346,"description":"SUR-REPLY to Reply to Response re 114 MOTION to Dismiss Pursuant to Fed. 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R. Civ. P. 12(b)(6) and 35 U.S.C. 101 and Joinder in Defendant Core Scientific, Inc.'s Second Renewed Motion to Dismiss filed by Key Patent Innovations Ltd., Malikie Innovations Ltd.. (Henry, Claire) (Entered: 07/21/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/470961003/","id":470961003,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/70244989/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/486353041/","id":486353041,"tags":[],"absolute_url":"/docket/70244989/122/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-07-15T12:22:35.613319-07:00","date_modified":"2026-08-11T13:45:23.676893-07:00","sha1":"f975a6e4dd564ae2315fcaf6e7dd97e851ddc485","page_count":16,"file_size":307459,"filepath_local":"recap/gov.uscourts.txed.237820/gov.uscourts.txed.237820.122.0_1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.txed.237820/gov.uscourts.txed.237820.122.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 2:25-cv-00519-JRG-RSP         Document 122    Filed 07/15/26   Page 1 of 16 PageID #:\n                                          3781\n\n\n\n                          IN THE UNITED STATES DISTRICT COURT\n                           FOR THE EASTERN DISTRICT OF TEXAS\n                                   MARSHALL DIVISION\n\n Malikie Innovations Ltd. and                  \u00a7\n Key Patent Innovations Ltd.,                  \u00a7\n                                               \u00a7\n                   Plaintiffs,                 \u00a7\n                                               \u00a7      Case No. 2:25-CV-519-JRG-RSP\n        v.                                     \u00a7\n                                               \u00a7      JURY TRIAL DEMANDED\n Core Scientific, Inc. and                     \u00a7\n CoreWeave, Inc.                               \u00a7\n                                               \u00a7\n                   Defendants.                 \u00a7\n                                               \u00a7\n Core Scientific, Inc.,                        \u00a7\n                                               \u00a7\n                   Defendant and Third-Party   \u00a7\n                   Plaintiff,                  \u00a7\n                                               \u00a7\n        v.                                     \u00a7\n                                               \u00a7\n CoreWeave, Inc.                               \u00a7\n                                               \u00a7\n                   Third-Party Defendant.      \u00a7\n\n\n\n       REPLY IN SUPPORT OF CORE SCIENTIFIC, INC.\u2019S MOTION TO DISMISS\n              PURSUANT TO FED. R. CIV. P. 12(b)(6) AND 35 U.S.C. \u00a7 101\n\fCase 2:25-cv-00519-JRG-RSP             Document 122          Filed 07/15/26        Page 2 of 16 PageID #:\n                                              3782\n\n\n\n                                        TABLE OF CONTENTS\n\n\n\n I.    The 960 and 062 Patent Claims Fail Both Alice Steps Under Plaintiffs\u2019 Analysis ................ 2\n\n II.   The 827 and 370 Patent Claims Fail Both Alice Steps Under Plaintiffs\u2019 Analysis ................ 5\n\n III. The 286 Patent Claims Fail Both Alice Steps Under Plaintiffs\u2019 Analysis .............................. 9\n\fCase 2:25-cv-00519-JRG-RSP                          Document 122                  Filed 07/15/26               Page 3 of 16 PageID #:\n                                                           3783\n\n\n\n                                                  TABLE OF AUTHORITIES\n\n\n Alice Corp. Pty. v. CLS Bank Int\u2019l, 573 U.S. 208 (2014) ..................................................... 4, 8, 10\n\n BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281 (Fed. Cir. 2018) ............................................. 8\n\n ChargePoint, Inc. v. SemaConnect, Inc., 920 F.3d 759 (Fed. Cir. 2019) ................................. 5, 10\n\n Diamond v. Diehr, 450 U.S. 175 (1981) ......................................................................................... 7\n\n Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344 (Fed. Cir. 2014) ......... 6, 7\n\n Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016)......................................... 4, 5, 10\n\n In re Board of Trs. of Leland Stanford Junior Univ., 989 F.3d 1367 (Fed. Cir. 2021) ......... passim\n\n In re Board of Trs. of Leland Stanford Junior Univ., 991 F.3d 1245 (Fed. Cir. 2021) .................. 9\n\n Infernal Tech., LLC v. Sony Interactive Ent. LLC, No. 2:19-CV-00248-JRG, 2021 WL\n\n    5804262 (E.D. Tex. Dec. 7, 2021) .............................................................................................. 4\n\n Intell. Ventures I LLC v. Cap. One Bank (USA), 792 F.3d 1363 (Fed. Cir. 2015) ..................... 5, 7\n\n Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335 (Fed. Cir. 2018) ........................................... 6\n\n Optis Cellular Tech. LLC v. Apple Inc., 139 F.4th 1363 (Fed Cir. 2025) ...................................... 7\n\n Parker v. Flook, 437 U.S. 584 (1978).................................................................................... passim\n\n PersonalWeb Tech. LLC v. Google LLC, 8 F.4th 1310 (Fed. Cir. 2021) ............................... passim\n\n RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322 (Fed. Cir. 2017) ........................................ 3, 7\n\n SAP America, Inc. v. Investpic, LLC, 898 F.3d 1161 (Fed. Cir. 2018) ............................. 1, 3, 5, 10\n\n Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138 (Fed. Cir. 2016) ......................... 3, 7, 10\n\n TQP Dev., LLC v. Intuit Inc., No. 2:12\u2013CV\u2013180\u2013WCB, 2014 WL 651935 (E.D. Tex.\n\n    Feb. 19, 2014) ............................................................................................................................. 8\n\n Trinity Info Media, LLC v. Covalent, Inc., 72 F.4th 1355 (Fed. Cir. 2023) ............................. 2, 10\n\n Univ. of Fla. Research Found., Inc. v. GE Co., 916 F.3d 1363 (Fed. Cir. 2019) ........................... 6\n\fCase 2:25-cv-00519-JRG-RSP         Document 122        Filed 07/15/26        Page 4 of 16 PageID #:\n                                          3784\n\n\n\n                                TABLE OF ABBREVIATIONS\n\n\n\n  Malikie Innovations Ltd. and Key Patent Innovations Ltd.                     Plaintiffs\n  Core Scientific, Inc.                                                        Core Scientific\n  Core Scientific\u2019s Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6)     Mot.\n  and 35 U.S.C. \u00a7 101 (Dkt. 114)\n  Plaintiffs\u2019 Opposition to Core Scientific\u2019s Motion to Dismiss (Dkt. 119)     Opp.\n  U.S. Patent No. 7,372,960                                                    960 patent\n  U.S. Patent No. 8,666,062                                                    062 patent\n  U.S. Patent No. 8,788,827                                                    827 patent\n  U.S. Patent No. 10,284,370                                                   370 patent\n  U.S. Patent No. 8,532,286                                                    286 patent\n  960, 062, 827, 370, and 286 patents                                          Challenged Patents\n\n\n\n                                           EMPHASIS\n\n All emphasis added unless otherwise specified\n\fCase 2:25-cv-00519-JRG-RSP           Document 122         Filed 07/15/26      Page 5 of 16 PageID #:\n                                            3785\n\n\n\n         Mathematical algorithms, no matter how novel or groundbreaking they may be, are not\n\n ineligible for patent protection because they are part of the \u201cbasic tools of scientific and\n\n technological work.\u201d Parker v. Flook, 437 U.S. 584, 591-92 (1978). At bottom, whatever novelty\n\n there may be in the claims of the Challenged Patents is found only in the algorithms. And a claim\n\n that is \u201cdirected essentially to a method of calculating, using a mathematical formula, even if the\n\n solution is for a specific purpose, \u2026 is nonstatutory.\u201d Id. at 595.\n\n         Plaintiffs\u2019 arguments to the contrary, asserted in both the FAC and again in the\n\n Opposition, do not compel a different conclusion. Repeated references to the claims being\n\n directed at \u201ctechnological solutions\u201d to \u201ctechnological problems\u201d are unavailing because those\n\n alleged \u201ctechnological solutions\u201d are the algorithms themselves. That is not enough to avoid\n\n invalidity under \u00a7 101. Parker, 437 U.S. at 595, n.18 (\u201cVery simply, our holding today is that a\n\n claim for an improved method of calculation, even when tied to a very specific end use, is\n\n unpatentable subject matter under \u00a7 101.\u201d); SAP America, Inc. v. Investpic, LLC, 898 F.3d 1161,\n\n 1163 (Fed. Cir. 2018) (\u201cThe claims here are ineligible because their innovation is an innovation\n\n in ineligible subject matter.\u201d).\n\n         Plaintiffs\u2019 attempts to avoid dismissal by reference to alleged factual and claim\n\n construction disputes also must fail. Even if the inventions described in the patents were\n\n groundbreaking and resulted in more efficient calculating, that does not change what is specified\n\n in the claims\u2014improved mathematical algorithms. PersonalWeb Tech. LLC v. Google LLC, 8\n\n F.4th 1310, 1319 (Fed. Cir. 2021) (rejecting argument that \u201cimprovements [described] in the\n\n specification\u201d prevented dismissal because the claims lacked an \u201cinventive concept in the non-\n\n abstract application realm\u201d). As to claim construction, Plaintiffs have failed to show how\n\n construction of the few terms they identify would impact the understanding of the claims. Trinity\n\n\n\n                                                   1\n\fCase 2:25-cv-00519-JRG-RSP           Document 122         Filed 07/15/26      Page 6 of 16 PageID #:\n                                            3786\n\n\n\n Info Media, LLC v. Covalent, Inc., 72 F.4th 1355, 1360-61 (Fed. Cir. 2023). Consequently, the\n\n Court should grant Core Scientific\u2019s Motion to Dismiss.\n\n I.     The 960 and 062 Patent Claims Fail Both Alice Steps Under Plaintiffs\u2019 Analysis\n\n        ACS concedes that the only claims from these patents that it is asserting are claims 3 and\n\n 6 of the 960 patent and claims 1-4, 6, and 7 of the 062 patent. Opp. at 14, n.7. Thus, independent\n\n claim of the 960 patent is indeed representative. Mot. at 14-16. 1 The only difference between\n\n claim 3 and independent claim 1 of the 062 patent is th at the latter is written in terms of a\n\n processor executing the instructions making up the algorithm. 2\n\n        Claim 3 of the 960 patent is unquestionably directed to an algorithm. The claimed steps\n\n take an input (step a), perform mathematical operations on the input to obtain a first result (steps\n\n b and c), perform further mathematical operations on that result to obtain a second result (step d),\n\n and use the second result in a cryptographic operation (step e). 960 patent, claim 3. There is no\n\n material difference between claim 3 and the claim invalidated in Parker, which similarly\n\n performed mathematical operations on an input to obtain a result (an \u201cupdated alarm limit\u201d) for\n\n use in a particular field (a \u201cprocess involving the catalytic chemical conversion of\n\n hydrocarbons\u201d). 437 U.S. at 596-97 (listing claim). Nor is there a material difference between\n\n claim 3 and the claim invalidated in Stanford I. That claim also performed mathematical\n\n operations on an input (\u201callele information regarding genotypes\u201d) to obtain a result (\u201ca haplotype\n\n\n\n 1\n         Core Scientific reserves the right to challenge any non-asserted claims as part of an\n invalidity counterclaim if its motion to dismiss is not granted.\n 2\n         Plaintiffs\u2019 dependent claims argument is not persuasive. Reviewing claims 6 of the 960\n patent and claims 2-4, 6 and 7 of the 062 patent shows that they merely add further details\n regarding the algorithm, such as the inputs to the algorithm (062, claims 2, 3), the makeup and\n role of the finite field in the algorithm (960 claim 6, 062 claim 4), and the field of use (062,\n claims 6, 7). These claims do not add \u201csignificantly more\u201d to the abstract idea. In re Board of\n Trs. of Leland Stanford Junior Univ., 989 F.3d 1367, 1372 (Fed. Cir. 2021) (\u201cStanford I\u201d).\n                                                   2\n\fCase 2:25-cv-00519-JRG-RSP           Document 122         Filed 07/15/26       Page 7 of 16 PageID #:\n                                            3787\n\n\n\n phase for at least member of the family\u201d), storing it in computer memory, and providing the\n\n haplotype phase upon request. 989 F.3d at 1370.\n\n        Claim 3 and those in Parker and Stanford I are directed to \u201cmathematical algorithms for\n\n performing calculations,\u201d which \u201cwithout more, are patent ineligible.\u201d Id. at 1372; see\n\n RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327 (Fed. Cir. 2017) (\u201cA process that\n\n started with data, added an algorithm, and ended with a new form of data was directed to an\n\n abstract idea.\u201d). That holds true here. There is nothing \u201cmore\u201d in claim 3. That the claim requires\n\n that the result be \u201cused\u201d in a \u201ccryptographic operation\u201d is of no moment because specifying that\n\n the result is \u201cfor a specific purpose\u201d cannot save the claim if the claim is \u201cdirected essentially to\n\n a method of calculating, using a mathematical formula.\u201d Parker, 437 U.S. at 595.\n\n        Plaintiffs argue that the claim is a technological solution to a technical problem. Even\n\n taken as true for argument\u2019s sake, that does not save the claims because the \u201ctechnological\n\n solution\u201d is the algorithm itself. It matters not whether the algorithm is novel or groundbreaking.\n\n In Stanford I, Stanford asserted that the claimed invention was \u201cnovel\u201d and enabled scientists to\n\n \u201cascertain more haplotype information than was previously possible.\u201d 989 F.3d at 1373. But\n\n even \u201caccepting the argument that the claimed process results in improved data, we are not\n\n persuaded that claim 1 is not directed to an abstract mathematical calculation.\u201d Id., citing\n\n Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (\u201c[A] claim for a\n\n new abstract idea is still an abstract idea\u201d); SAP, 898 F.3d at 1170 (\u201c[P]atent law does not protect\n\n such claims, without more, no matter how groundbreaking the advance.\u201d). Here, claim 3 covers\n\n at most a \u201cnew abstract idea.\u201d\n\n        Nor does claim 3 improve the functioning of computers, as Plaintiffs allege. There is\n\n nothing in the claims or the patents that improves computer functioning per se. The 960 patent\n\n\n\n                                                   3\n\fCase 2:25-cv-00519-JRG-RSP              Document 122      Filed 07/15/26       Page 8 of 16 PageID #:\n                                               3788\n\n\n\n confirms that it uses generic processors and memory. 960 patent, 6:46-48. Instead, the alleged\n\n improvement is the \u201cspecialized reduction algorithms.\u201d Id. at 7:43-45. But even if an algorithm\n\n results in a faster or more efficient way to obtain the claimed reduced result of a finite field,\n\n faster or better algorithms are still abstract ideas. At most, the claims merely \u201cenhance[] an\n\n ineligible concept;\u201d they are not \u201cimprovement[s] on a technological process.\u201d Stanford I, 989\n\n F.3d at 1373; PersonalWeb, 8 F.4th at 1316 (\u201cThe claims do this in a computer environment, but\n\n that doesn\u2019t transfigure an idea out of the realm of abstraction\u201d). 3 As in PersonalWeb, whether\n\n the algorithm results in a more efficient process on a computer does not \u201crender an abstract idea\n\n less abstract.\u201d Id. at 1319. The focus of the claims here is \u201cnot on \u2026 an improvement in\n\n computers as tools, but on certain independently abstract ideas that use computers as tools,\u201d and\n\n that \u201cfails [Alice 4] step one.\u201d Id.\n\n         The claims here, contrary to Plaintiffs\u2019 arguments, are not like those in Enfish, LLC v.\n\n Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016), and Infernal Tech., LLC v. Sony Interactive\n\n Ent. LLC, No. 2:19-CV-00248-JRG, 2021 WL 5804262 (E.D. Tex. Dec. 7, 2021). In Enfish, the\n\n claims required \u201ca data storage and retrieval system for a computer memory\u201d with \u201ca self-\n\n referential table for a computer database.\u201d 822 F.3d at 1336\u201337. Therefore, the claimed table \u201cis\n\n a specific type of data structure designed to improve the way a computer stores and retrieves\n\n data in memory.\u201d Id. at 1339. Similarly, in Infernal Tech., the claimed process \u201cactually\n\n\n\n\n 3\n         Plaintiffs\u2019 claim construction argument also fails. Plaintiffs assert that the terms \u201cmachine\n words\u201d and \u201cwordsized operation\u201d show that the claims are intended to be performed on a\n computer. Opp. at 9-11. Even if true, an algorithm performed on a generic computer is still\n patent ineligible. Stanford I, 989 F.3d at 1374 (\u201c[C]laim 1 neither requires, nor results in, a\n specialized computer with a specialized memory or processor.\u201d). That applies here.\n 4\n         Alice Corp. Pty. v. CLS Bank Int\u2019l, 573 U.S. 208 (2014).\n\n\n                                                   4\n\fCase 2:25-cv-00519-JRG-RSP           Document 122         Filed 07/15/26      Page 9 of 16 PageID #:\n                                            3789\n\n\n\n improves graphics rendering in computers\u201d and thus is \u201can improvement to the functionality of\n\n computers in rendering realistic graphics.\u201d 2021 WL 5804262, at *4. Thus, the claimed\n\n technology in Enfish and Infernal Tech. are \u201cimprovement[s] to computer functionality itself,\u201d\n\n Enfish, 822 F.3d at 1336. Claim 3, in contrast, is an alleged improved algorithm for finite field\n\n calculations; it does not improve a computer\u2019s ability to perform any other tasks. \u201c[O]ur\n\n precedent is clear that merely adding computer functionality to increase the speed or efficiency\n\n of the process does not confer patent eligibility on an otherwise abstract idea.\u201d Intell. Ventures I\n\n LLC v. Cap. One Bank (USA), 792 F.3d 1363, 1370 (Fed. Cir. 2015).\n\n        Turning to Alice step two, the Federal Circuit\u2019s analysis in PersonalWeb is apt here:\n\n \u201c[w]hat else is there in the claims before us? \u2026 As to the subject-matter question, not much.\u201d 8\n\n F.4th at 1319. There is \u201cnothing \u2018inventive\u2019 about any claim details, individually or in\n\n combination, that are not themselves abstract ideas.\u201d Id. Again, whether the claimed algorithm\n\n is novel is not relevant because the claimed \u201cinnovation is an innovation in ineligible subject\n\n matter.\u201d SAP, 898 F.3d at 1163. And \u201c[t]hat fails step two.\u201d PersonalWeb, 8 F.4th at 1319. 5\n\n        Accordingly, the asserted claims of the 960 and 062 patents fail both steps of the Alice\n\n inquiry because they recite abstract, mathematical operations that are patent-ineligible.\n\n II.    The 827 and 370 Patent Claims Fail Both Alice Steps Under Plaintiffs\u2019 Analysis\n\n        Plaintiffs\u2019 arguments for the 827 and 370 patents also fail, as, at most, the claims are\n\n\n\n\n 5\n         Whether in step one or two, Plaintiffs\u2019 arguments regarding the specification cannot save\n the claims. The specification \u201ccannot be used to import details from the specification if those\n details are not claimed.\u201d ChargePoint, Inc. v. SemaConnect, Inc., 920 F.3d 759, 769 (Fed. Cir.\n 2019). The alleged improvements of eliminating the need for \u201cduplicating the bulk of the engine\n instructions (program)\u201d and \u201cfinite field elements [that can] be consistently stored in registers of\n the same word length,\u201d Opp. at 5\u20136, are not claimed. Alleging improvements that are stated in\n the specification and not claimed cannot defeat a motion to dismiss. PersonalWeb, 8 F.4th at\n 1319 (rejecting the same argument Plaintiffs make here).\n                                                   5\n\fCase 2:25-cv-00519-JRG-RSP            Document 122 Filed 07/15/26              Page 10 of 16 PageID\n                                           #: 3790\n\n\n\n directed to an improved digital signature verification algorithm and nothing \u201cmore.\u201d 6 Claim 1 of\n\n the 827 patent recites 3 steps: (1) \u201creceiving\u201d a signature without a public key from a message;\n\n (2) \u201cobtaining\u201d an elliptic curve point from the signature; and (3) \u201cgenerating\u201d a public key of\n\n the signer from the elliptic curve point and a hash value of the message. These types of process\n\n steps have repeatedly been found abstract. Univ. of Fla. Research Found., Inc. v. GE Co., 916\n\n F.3d 1363, 1367 (Fed. Cir. 2019) (collecting cases finding steps such as collecting, analyzing,\n\n manipulating, and displaying data abstract).\n\n        As Plaintiffs acknowledge, the alleged improvement instead lies in recovering the public\n\n key Q from the signature itself using the formula \ud835\udc44\ud835\udc44 = \ud835\udc5f\ud835\udc5f \u22121 (\ud835\udc60\ud835\udc60\ud835\udc60\ud835\udc60 \u2212 \ud835\udc52\ud835\udc52\ud835\udc52\ud835\udc52). Opp. at 18-19. Once again,\n\n the mathematical formula\u2014the algorithm\u2014is the focus of the claim. That is not enough.\n\n Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344, 1351 (Fed. Cir. 2014)\n\n (\u201c[A] process that employs mathematical algorithms to manipulate existing information to\n\n generate additional information is not patent eligible\u201d); Parker, 437 U.S. at 595.\n\n        Plaintiffs again argue about the claim being a technological solution to a technological\n\n problem. Opp. at 17\u201319. But like the analysis for the 960 and 062 patents, even accepting that as\n\n true for purposes of this motion, the alleged improvement here is to the pre-existing Elliptic\n\n Curve Digital Signature Algorithm (ECDSA) itself: recovering the public key for faster\n\n verification. 827 patent, 4:16-27 (stating that \u201cimprovement of ECDSA verification time is\n\n important\u201d); 5:63-65 (\u201cThe present invention is exemplified by reference to verification of digital\n\n\n\n 6\n         Here too, Plaintiffs concede that only claims 1-5 of each patent are asserted. Opp. at 18,\n n.11, 24, n. 16. Claim 1 of the 827 patent is thus representative of the claims. Claim 1 of the 370\n patent contains the same algorithmic steps and merely adds generic \u201cprocessor,\u201d \u201ccomputing\n device,\u201d and \u201cnetwork\u201d hardware, which the Federal Circuit has repeatedly found cannot render\n a claim non-abstract. Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1345 (Fed. Cir. 2018).\n Dependent claims 2-5 in each patent are identical and only add additional details concerning the\n algorithm itself or its field of use. Mot. at 21-22.\n                                                   6\n\fCase 2:25-cv-00519-JRG-RSP            Document 122 Filed 07/15/26              Page 11 of 16 PageID\n                                           #: 3791\n\n\n\n signatures, in particular those signatures generated using ECDSA\u201d). And a \u201cclaim for a new\n\n abstract idea is still an abstract idea.\u201d Synopsys, 839 F.3d at 1151. Unlike in Enfish, the claims\n\n here do not improve the functionality of the computer itself. Stanford I, 989 F.3d at 1374\n\n (\u201c[C]laim 1 neither requires, nor results in, a specialized computer with a specialized memory or\n\n processor.\u201d); Intell. Ventures, 792 F.3d at 1370 (holding that increasing the \u201cspeed or efficiency\n\n of the process does not confer patent eligibility on an otherwise abstract idea\u201d). 7\n\n        Plaintiffs\u2019 argument that ECDSA is computer-centric technology does not change the\n\n outcome. PersonalWeb, 8 F.4th at 1316 (\u201cThe claims do this in a computer environment, but that\n\n doesn\u2019t transfigure an idea out of the realm of abstraction\u201d); Optis Cellular Tech. LLC v. Apple\n\n Inc., 139 F.4th 1363, 1380 (Fed Cir. 2025) (\u201c[T]he claims are directed to reciting an equation\n\n that outputs a value to be used as the specific start position for decoding information in a cellular\n\n network. This is an ineligible mathematical formula.\u201d); Digitech, 758 F.3d at 1351 (holding that\n\n \u201ca process that employs mathematical algorithms to manipulate existing information to generate\n\n additional information is not patent eligible.\u201d). There is nothing \u201cmore\u201d in the claims here other\n\n than applying the allegedly improved algorithm to input data to obtain output data (a public key).\n\n The claims are thus directed at a patent-ineligible mathematical algorithm. Parker, 437 U.S. at\n\n 595; see RecogniCorp, 855 F.3d at 1327 (finding that a process that, like here, \u201cstarted with data,\n\n added an algorithm, and ended with a new form of data\u201d is an abstract idea).\n\n        Plaintiffs\u2019 reliance on Diamond v. Diehr, 450 U.S. 175 (1981) is off-base. Those claims\n\n were directed to transforming \u201craw, uncured synthetic rubber, into a different state\u201d and the\n\n applicants sought \u201cpatent protection for a process of curing synthetic rubber.\u201d Id. at 184\u201387.\n\n\n\n\n 7\n         The claimed invention uses only \u201cgeneral purpose computers connected to a network or\n specialized devices such as cell phones, pagers, PDA\u2019s, or the like.\u201d 827 patent, 6:16-20.\n                                                   7\n\fCase 2:25-cv-00519-JRG-RSP            Document 122 Filed 07/15/26              Page 12 of 16 PageID\n                                           #: 3792\n\n\n\n Thus, the claims were directed to an \u201cindustrial process.\u201d Id. at 191\u201393. The claims here are not\n\n remotely similar. Instead, \u201c[t]he sole practical application of the algorithm [(i.e., the claimed\n\n improved version of the ECDSA] was in connection with the programming of a general purpose\n\n digital computer\u2026 which cannot be the subject of a patent.\u201d Id. at 185\u201386.\n\n        TQP Dev., LLC v. Intuit Inc., No. 2:12\u2013CV\u2013180\u2013WCB, 2014 WL 651935 (E.D. Tex.\n\n Feb. 19, 2014) does not hold otherwise. The claims in TQP were patent eligible, not because the\n\n claims are in the field of data encryption, but because they \u201cinvolve[] a way of making computer\n\n communication itself more effective by making that communication more secure.\u201d 2014 WL\n\n 651935, at *7. The claimed improvement here is not to the computer itself but is an alleged\n\n improvement to an algorithm (ECDSA) that merely invokes computers as a tool.\n\n        As for Alice step two, Plaintiffs merely reiterate the background and the claimed\n\n advantage of the invention and conclude that the claim \u201ccovers a patent-eligible inventive\n\n concept.\u201d Opp. at 22-23. But reviewing claim 1 reveals that other than the allegedly improved\n\n ECDSA for recovering the public key, there are no \u201cadditional features\u201d to \u201ctransform the\n\n claimed abstract idea into a patent-eligible application.\u201d Alice, 573 U.S. at 221. Indeed, the\n\n entirety of the claim is the algorithm, and as such it fails step two as a matter of law. \u201c[T]he\n\n relevant inquiry is not whether the claimed invention as a whole is unconventional or non-\n\n routine,\u201d but \u201cwhether the claim limitations other than the invention\u2019s use of the ineligible\n\n concept to which it was directed were well-understood, routine and conventional.\u201d BSG Tech\n\n LLC v. Buyseasons, Inc., 899 F.3d 1281, 1290 (Fed. Cir. 2018). Here, there are simply no claim\n\n limitations beyond the algorithm\u2019s application to the input data to produce the public key. 8\n\n\n\n\n 8\n        Plaintiffs make no arguments that claim construction is required and thus have waived\n any such argument.\n                                                   8\n\fCase 2:25-cv-00519-JRG-RSP            Document 122 Filed 07/15/26             Page 13 of 16 PageID\n                                           #: 3793\n\n\n\n        Accordingly, the asserted claims of the 827 and 370 patents fail both steps of the Alice\n\n inquiry because they recite abstract, mathematical operations not eligible for patent protection.\n\n III.   The 286 Patent Claims Fail Both Alice Steps Under Plaintiffs\u2019 Analysis\n\n        Claim 1 of the 286 patent is not materially different from all the claims analyzed above: it\n\n claims an improved way of performing a Montgomery-style reduction mathematical algorithm.\n\n Claim 1 9 contains 3 steps: (1) obtaining an operand; (2) computing a modified operand using a\n\n reduction value; and (3) outputting the modified operand. The computing step involves the\n\n alleged improvement to the standard Montgomery reduction algorithm. This is another example\n\n of a non-eligible improvement to an abstract idea, as admitted in the patent itself. 286 patent,\n\n 3:21-22 (the objective of the invention is \u201c[t]o improve the reduction efficiency of a\n\n Montgomery machine\u201d). Such an improvement \u201cdoes not qualify as an improvement to a\n\n technological process\u201d but rather is \u201can enhancement to the abstract mathematical calculation []\n\n itself.\u201d In re Board of Trs. of Leland Stanford Junior Univ., 991 F.3d 1245, 1251 (Fed. Cir.\n\n 2021). Even assuming the claimed improved algorithm \u201cyields different or better results,\u201d it is\n\n still a mathematical algorithm and \u201cdoes not render [the claim] patent eligible.\u201d Id.\n\n        Plaintiffs cite the specification in arguing that the claim describes \u201chow a computer\n\n performs a new kind of Montgomery-style reduction,\u201d which is an alleged technological\n\n improvement. Opp. at 26\u201328. Plaintiffs assert that the improvement \u201ccan reduce the number of\n\n computations and registers needed\u201d and the improved method makes it convenient to perform\n\n modified reduction in some known computer architectures. Id. Even accepting that is true, first,\n\n an \u201cimproved mathematical analysis\u201d (i.e., reduced number of computations) is not patentable\n\n\n\n 9\n          Plaintiffs concede that only claim 1 and dependent claims 5, 6, and 9 are asserted. Opp. at\n 30. Claim 1 is therefore plainly representative, as the dependent claims add only features directed\n to the field of use (claims 5, 6) or the type of calculation used (claim 9). Mot. at 27-28.\n                                                  9\n\fCase 2:25-cv-00519-JRG-RSP            Document 122 Filed 07/15/26               Page 14 of 16 PageID\n                                           #: 3794\n\n\n\n subject matter. SAP, 898 F.3d at 1168. Second, \u201c[t]he \u00a7 101 inquiry must focus on the language\n\n of the Asserted Claims themselves.\u201d Synopsys, 839 F.3d at 1149, and details from the\n\n specification cannot be imported into the claims. ChargePoint, 920 F.3d at 769. Here, claim 1\n\n has none of the alleged technological improvements. Plaintiffs\u2019 analogy to Enfish is again\n\n unpersuasive because while the claims there \u201cimprove the way a computer stores and retrieves\n\n data in memory,\u201d 822 F.3d at 1339, the claims here, as Plaintiffs tacitly admit, only recite an\n\n improved mathematical algorithm implemented on a generic computer. Opp. at 27-28; see\n\n Trinity, 72 F.4th at 1362-63. Once again, a new and improved algorithm executed on a generic\n\n computer is still non-eligible. Synopsys, 839 F.3d at 1151 (\u201c[A] claim for a new abstract idea is\n\n still an abstract idea\u201d). Claim 1 covers at most a \u201cnew abstract idea,\u201d and thus fails step one. 10\n\n        For step two, Plaintiffs again make conclusory statements that the claim recites an\n\n inventive concept. But they fail to identify any \u201cadditional features\u201d to \u201ctransform the claimed\n\n abstract idea into a patent-eligible application.\u201d Alice, 573 U.S. at 221. There is \u201cnot much\u201d else\n\n in the claim other than the abstract idea, which fails step two. PersonalWeb, 8 F.4th at 1319; see\n\n Stanford I, 989 F.3d at 1373-74 (holding that \u201csimply storing information and providing it upon\n\n request\u201d does not transform the abstract idea into eligible subject matter).\n\n        Accordingly, the asserted claims of the 286 patent fail both steps of the Alice inquiry\n\n because they recite abstract, mathematical operations not eligible for patent protection.\n\n\n\n 10\n         Plaintiffs identify \u201cleast significant word\u201d and \u201cword\u201d as terms that may require\n construction, but fail to propose any constructions, and fail to explain how constructions would\n change the analysis. Opp. at 27-28. The 286 patent concedes that the invention may be\n \u201cimplemented as an apparatus in hardware or in software (computer readable instructions\n embodied in/on a computer readable medium).\u201d 286 patent, 4:2-5. At bottom, claim construction\n will not matter because, even assuming the claim is directed at computer-based technology, \u201can\n abstract idea does not become nonabstract by limiting the invention to a particular field of use or\n technological environment.\u201d Recentive Analytics, Inc. v. Fox Corp., 134 F.4th 1205, 1213 (Fed.\n Cir. 2025).\n                                                   10\n\fCase 2:25-cv-00519-JRG-RSP   Document 122 Filed 07/15/26            Page 15 of 16 PageID\n                                  #: 3795\n\n\n\n\n    Dated: July 15, 2026                  Respectfully submitted,\n                                          /s/ Brian E. Ferguson\n                                          Brian E. Ferguson\n                                          KING & SPALDING LLP\n                                          1700 Pennsylvania Avenue, NW\n                                          Suite 900\n                                          Washington, D.C. 20006\n                                          Telephone: (202) 737-0500\n                                          Email: bferguson@kslaw.com\n\n                                          Rex A. Mann\n                                          Texas Bar No. 24075509\n                                          KING & SPALDING LLP\n                                          2601 Olive Street\n                                          Suite 2300\n                                          Dallas, TX 75201\n                                          Tel.: (214) 764-4600\n                                          Email: rmann@kslaw.com\n\n                                          John Tyler Boyce\n                                          Texas Bar No. 24127214\n                                          KING & SPALDING LLP\n                                          1100 Louisiana, Suite 4100\n                                          Houston, TX 77002\n                                          Tel.: (713) 276-7324\n                                          Email: tboyce@kslaw.com\n\n                                          Attorneys for Core Scientific, Inc.\n\n\n\n\n                                     11\n\fCase 2:25-cv-00519-JRG-RSP          Document 122 Filed 07/15/26            Page 16 of 16 PageID\n                                         #: 3796\n\n\n\n                                 CERTIFICATE OF SERVICE\n\n        I certify that a true and correct copy of the foregoing document has been served on\n counsel of record, who are deemed to have consented to electronic service, on July 15, 2026, via\n electronic filing using the Court\u2019s CM/ECF system.\n\n                                             /s/ Brian E. Ferguson\n\n                                             Brian E. Ferguson\n\n\n\n\n                                                12\n\f","ocr_status":2,"date_upload":"2026-07-27T07:29:48.808403-07:00","document_number":"122","attachment_number":null,"pacer_doc_id":"175015536242","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Reply to Response to Motion","acms_document_guid":""}],"date_created":"2026-07-15T12:22:35.552613-07:00","date_modified":"2026-08-26T18:56:50.187438-07:00","date_filed":"2026-07-15","time_filed":"13:19:56","entry_number":122,"recap_sequence_number":"2026-07-15.001","pacer_sequence_number":340,"description":"REPLY to Response re 114 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) and 35 U.S.C. 101 filed by Core Scientific, Inc.. (Ferguson, Brian) (Entered: 07/15/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/470960949/","id":470960949,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/70244989/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/486352987/","id":486352987,"tags":[],"absolute_url":"/docket/70244989/123/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-07-15T12:22:30.099913-07:00","date_modified":"2026-07-15T12:22:30.108315-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"123","attachment_number":null,"pacer_doc_id":"175015536315","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Reply to Response to Motion","acms_document_guid":""}],"date_created":"2026-07-15T12:22:30.061029-07:00","date_modified":"2026-08-26T18:56:50.215616-07:00","date_filed":"2026-07-15","time_filed":"13:43:10","entry_number":123,"recap_sequence_number":"2026-07-15.002","pacer_sequence_number":343,"description":"REPLY to Response re 115 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) and 35 U.S.C. 101 and Joinder in Defendant Core Scientific, Inc.'s Second Renewed Motion to Dismiss filed by CoreWeave, Inc.. (Kessel, Adam) (Entered: 07/15/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/470389679/","id":470389679,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/70244989/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/485765397/","id":485765397,"tags":[],"absolute_url":"/docket/70244989/121/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-07-10T07:35:33.831178-07:00","date_modified":"2026-08-14T18:18:57.719624-07:00","sha1":"a632d38d95db91d0bef3b86dc0e30d08bd10a312","page_count":6,"file_size":991312,"filepath_local":"recap/gov.uscourts.txed.237820/gov.uscourts.txed.237820.121.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.txed.237820/gov.uscourts.txed.237820.121.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.txed.237820/485765397.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 2:25-cv-00519-JRG-RSP            Document 121       Filed 07/10/26     Page 1 of 6 PageID #:\n                                             3775\n\n\n\n                         IN THE UNITED STATES DISTRICT COURT\n                          FOR THE EASTERN DISTRICT OF TEXAS\n                                  MARSHALL DIVISION\n\n  MALIKIE INNOVATIONS LTD. and                    \u00a7\n  KEY PATENT INNOVATIONS LTD.,                    \u00a7\n                                                  \u00a7\n                  Plaintiffs,\n                                                  \u00a7\n  v.                                              \u00a7      CASE NO. 2:25-CV-00519-JRG-RSP\n  CORE SCIENTIFIC, INC.,                          \u00a7\n                                                  \u00a7\n                  Defendant.                      \u00a7\n\n                       THIRD AMENDED DOCKET CONTROL ORDER\n\n          Before the Court is the Parties\u2019 Joint Motion to Amend the Docket Control Order. Dkt.\n\n No. 117. Having considered the Motion, and noting its joint nature, the Court finds that it should\n\n be and hereby is GRANTED. Accordingly, it is\n\n          ORDERED that the following schedule of deadlines is in effect until further order of this\n\n Court:\n\n  Event                                            Current Date             Amended Date\n  *Jury Selection \u2013 9:00 a.m. in Marshall,         July 12, 2027            December 6, 2027\n  Texas\n  *Defendant to disclose final invalidity          7 days before Jury       7 days before Jury\n  theories, final prior art                        Selection                Selection\n  references/combinations, and final equitable\n  defenses with notice of the same filed with\n  the Court. 1\n  *Plaintiff to disclose final election of         10 days before Jury      10 days before Jury\n  Asserted Claims with notice of the same          Selection                Selection\n  filed with the Court.2\n  * If a juror questionnaire is to be used, an     May 24, 2027             October 20, 2027\n  editable (in Microsoft Word format)\n  questionnaire shall be jointly submitted to\n  the Deputy Clerk in Charge by this date.3\n  *Pretrial Conference \u2013 9:00 a.m. in Marshall,    May 18, 2027             October 14, 2027\n  Texas before Magistrate Judge Roy S. Payne\n  *Notify Court of Agreements Reached              May 10, 2027             October 7, 2027\n  During Meet and Confer\n   The parties are ordered to meet and confer\n  on any outstanding objections or motions in\n\n\n                                                  1\n\fCase 2:25-cv-00519-JRG-RSP            Document 121         Filed 07/10/26   Page 2 of 6 PageID #:\n                                             3776\n\n\n\n  Event                                              Current Date           Amended Date\n  limine. The parties shall advise the Court of\n  any agreements reached no later than 1:00\n  p.m. three (3) business days before the\n  pretrial conference.\n  *File Joint Pretrial Order, Joint Proposed         May 10, 2027           October 7, 2027\n  Jury Instructions, Joint Proposed Verdict\n  Form, Responses to Motions in Limine,\n  Updated Exhibit Lists, Updated Witness\n  Lists, and Updated Deposition Designations\n  *File Notice of Request for Daily Transcript       May 3, 2027            September 30, 2027\n  or Real Time Reporting.\n  If a daily transcript or real time reporting of\n  court proceedings is requested for trial, the\n  party or parties making said request shall file\n  a notice with the Court and e-mail the Court\n  Reporter, Shawn McRoberts, at\n  shawn_mcroberts@txed.uscourts.gov.\n  File Motions in Limine                             April 26, 2027         September 23, 2027\n  The parties shall limit their motions in limine\n  to issues that if improperly introduced at trial\n  would be so prejudicial that the Court could\n  not alleviate the prejudice by giving\n  appropriate instructions to the jury.\n  Serve Objections to Rebuttal Pretrial              April 26, 2027         September 23, 2027\n  Disclosures\n  Serve Objections to Pretrial Disclosures; and      April 19, 2027         September 16, 2027\n  Serve Rebuttal Pretrial Disclosures\n  Serve Pretrial Disclosures (Witness List,          April 5, 2027          September 2, 2027\n  Deposition Designations, and Exhibit List)\n  by the Party with the Burden of Proof\n  *Response to Dispositive Motions (including        March 29, 2027         August 26, 2027\n  Daubert Motions). Responses to dispositive\n  motions that were filed prior to the\n  dispositive motion deadline, including\n  Daubert Motions, shall be due in accordance\n  with Local Rule CV- 7(e), not to exceed the\n  deadline as set forth in this Docket Control\n  Order.4 Motions for Summary Judgment\n  shall comply with Local Rule CV-56.\n  *File Motions to Strike Expert Testimony           March 15, 2027         August 12, 2027\n  (including Daubert Motions)\n  No motion to strike expert testimony\n  (including a Daubert motion) may be filed\n  after this date without leave of the Court.\n  *File Dispositive Motions                          March 15, 2027         August 12, 2027\n\n\n                                                     2\n\fCase 2:25-cv-00519-JRG-RSP          Document 121        Filed 07/10/26   Page 3 of 6 PageID #:\n                                           3777\n\n\n\n  Event                                           Current Date           Amended Date\n  No dispositive motion may be filed after this\n  date without leave of the Court.\n  Motions shall comply with Local Rule CV-\n  56 and Local Rule CV-7. Motions to extend\n  page limits will only be granted in\n  exceptional circumstances. Exceptional\n  circumstances require more than agreement\n  among the parties.\n  Deadline to Complete Expert Discovery           March 8, 2027          August 6, 2027\n  Serve Disclosures for Rebuttal Expert           February 22, 2027      July 21, 2027\n  Witnesses\n  Serve Disclosures for Expert Witnesses by       February 1, 2027       July 1, 2027\n  the Party with the Burden of Proof\n  Deadline to Complete Fact Discovery and         February 1, 2027       July 1, 2027\n  File Motions to Compel Discovery\n  Comply with P.R. 3-7 (Opinion of Counsel        December 9, 2026       May 5, 2027\n  Defenses)\n  *Claim Construction Hearing \u2013 9:00 a.m.         November 18, 2026      April 15, 2027\n  in Marshall, Texas before Magistrate Judge\n  Roy S. Payne.\n  *Comply with P.R. 4-5(d) (Joint Claim           November 4, 2026       April 5, 2027\n  Construction Chart)\n  *Comply with P.R. 4-5(c) (Reply Claim           October 28, 2026       March 29, 2027\n  Construction Brief)\n  Comply with P.R. 4-5(b) (Responsive Claim       October 21, 2026       March 22, 2027\n  Construction Brief)\n  Comply with P.R. 4-5(a) (Opening Claim          October 7, 2026        March 8, 2027\n  Construction Brief) and Submit Technical\n  Tutorials (if any)\n  Good cause must be shown to submit\n  technical tutorials after the deadline to\n  comply with P.R. 4-5(a).\n  Deadline to Substantially Complete              October 7, 2026        March 8, 2027\n  Document Production and Exchange\n  Privilege Logs\n  Counsel are expected to make good faith\n  efforts to produce all required documents as\n  soon as they are available and not wait until\n  the substantial completion deadline.\n  Comply with P.R. 4-4 (Deadline to Complete      September 23, 2026     March 1, 2027\n  Claim Construction Discovery)\n  File Response to Amended Pleadings              September 16, 2026     February 22, 2027\n  *File Amended Pleadings                         September 2, 2026      February 8, 2027\n\n\n\n\n                                                  3\n\fCase 2:25-cv-00519-JRG-RSP            Document 121         Filed 07/10/26      Page 4 of 6 PageID #:\n                                             3778\n\n\n\n  Event                                         Current Date           Amended Date\n  It is not necessary to seek leave of Court to\n  amend pleadings prior to this deadline unless\n  the amendment seeks to assert additional\n  patents.\n  Comply with P.R. 4-3 (Joint Claim             August 26, 2026        February 1, 2027\n  Construction Statement)\n  Comply with P.R. 4-2 (Exchange                August 5, 2026         January 8, 2027\n  Preliminary Claim Constructions)\n  Comply with P.R. 4-1 (Exchange Proposed       July 15, 2026          December 18, 2026\n  Claim Terms)\n  Comply with P.R. 3-3 & 3-4 (Invalidity        None                   December 4, 2026\n  Contentions) as to remaining patents\n  Comply with P.R. 3-3 & 3-4 (Invalidity        July 1, 2026           December 4, 2026\n  Contentions) as to \u2019039 patent\n  Plaintiffs to serve supplemental P.R. 3-2     None                   September 30, 2026\n  Document Production (as to CoreWeave\n  only)\n  Plaintiffs to serve supplemental P.R. 3-1     None                   September 30, 2026\n  Infringement Contentions (as to CoreWeave\n  only)\n (*) indicates a deadline that cannot be changed without an acceptable showing of good\n cause. Good cause is not shown merely by indicating that the parties agree that the\n deadline should be changed.\n\n                                ADDITIONAL REQUIREMENTS\n\n         Mediation: While certain cases may benefit from mediation, such may not be appropriate\n for every case. The Court finds that the Parties are best suited to evaluate whether mediation will\n benefit the case after the issuance of the Court\u2019s claim construction order. Accordingly, the Court\n ORDERS the Parties to file a Joint Notice indicating whether the case should be referred for\n mediation within fourteen days of the issuance of the Court\u2019s claim construction order. As a\n part of such Joint Notice, the Parties should indicate whether they have a mutually agreeable\n mediator for the Court to consider. If the Parties disagree about whether mediation is appropriate,\n the Parties should set forth a brief statement of their competing positions in the Joint Notice.\n\n         Summary Judgment Motions, Motions to Strike Expert Testimony, and Daubert\n Motions: For each motion, the moving party shall provide the Court with two (2) hard copies of\n the completed briefing (opening motion, response, reply, and if applicable, sur-reply), excluding\n exhibits, in D-three-ring binders, appropriately tabbed. All documents shall be single-sided and\n must include the CM/ECF header. These copies shall be delivered to the Court within three (3)\n business days after briefing has completed. For expert-related motions, complete digital copies of\n the relevant expert report(s) and accompanying exhibits shall be submitted on a single flash drive\n to the Court. Complete digital copies of the expert report(s) shall be delivered to the Court no later\n than the dispositive motion deadline.\n\n\n\n                                                   4\n\fCase 2:25-cv-00519-JRG-RSP              Document 121          Filed 07/10/26       Page 5 of 6 PageID #:\n                                               3779\n\n\n\n         Indefiniteness: In lieu of early motions for summary judgment, the parties are directed to\n include any arguments related to the issue of indefiniteness in their Markman briefing, subject to\n the local rules\u2019 normal page limits.\n\n        Lead Counsel: The Parties are directed to Local Rule CV-11(a)(1), which provides that\n \u201c[o]n the first appearance through counsel, each party shall designate a lead attorney on the\n pleadings or otherwise.\u201d Additionally, once designated, a party\u2019s lead attorney may only be\n changed by the filing of a Motion to Change Lead Counsel and thereafter obtaining from the Court\n an Order granting leave to designate different lead counsel. The true lead counsel should be\n designated early and should not expect to parachute in as lead once the case has been largely\n developed.\n\n          Motions for Continuance: The following will not warrant a continuance nor justify a\n failure to comply with the discovery deadline:\n\n (a)     The fact that there are motions for summary judgment or motions to dismiss pending;\n\n (b)     The fact that one or more of the attorneys is set for trial in another court on the same day,\n         unless the other setting was made prior to the date of this order or was made as a special\n         provision for the parties in the other case;\n\n (c)     The failure to complete discovery prior to trial, unless the parties can demonstrate that it\n         was impossible to complete discovery despite their good faith effort to do so.\n\n        Amendments to the Docket Control Order (\u201cDCO\u201d): Any motion to alter any date on\n the DCO shall take the form of a motion to amend the DCO. The motion to amend the DCO shall\n include a proposed order that lists all of the remaining dates in one column (as above) and the\n proposed changes to each date in an additional adjacent column (if there is no change for a date\n the proposed date column should remain blank or indicate that it is unchanged). In other words,\n the DCO in the proposed order should be complete such that one can clearly see all the remaining\n deadlines and the changes, if any, to those deadlines, rather than needing to also refer to an earlier\n version of the DCO.\n\n          Joint Pretrial Order: In the contentions of the Parties included in the Joint Pretrial Order,\n the Plaintiff shall specify all allegedly infringed claims that will be asserted at trial. The Plaintiff\n shall also specify the nature of each theory of infringement, including under which subsections of\n 35 U.S.C. \u00a7 271 it alleges infringement, and whether the Plaintiff alleges divided infringement or\n infringement under the doctrine of equivalents. Each Defendant shall indicate the nature of each\n theory of invalidity, including invalidity for anticipation, obviousness, subject-matter eligibility,\n written description, enablement, or any other basis for invalidity. The Defendant shall also specify\n each prior art reference or combination of references upon which the Defendant shall rely at trial,\n with respect to each theory of invalidity. Other than as set forth in the above deadlines, the\n contentions of the Parties may not be amended, supplemented, or dropped without leave of the\n Court based upon a showing of good cause. The Parties in a case which has been consolidated for\n pre-trial purposes and which is moving towards a separate trial on the merits (subsequent to pre-\n trial) shall file, as an exhibit to the parties\u2019 Joint Pretrial Order, a list identifying all docket entries\n from the lead case that relate to the applicable member case.\n\n\n                                                      5\n\fCase 2:25-cv-00519-JRG-RSP           Document 121       Filed 07/10/26      Page 6 of 6 PageID #:\n                                            3780\n\n\n\n         Trial: All parties must appear in person at trial. All non-individual (including but not\n limited to corporate) parties must appear at trial through the presence in person of a designated\n representative. Once they have appeared, any representative of a non-individual party shall not be\n replacedSIGNED\n          or substituted without\n                    this 3rd day express leave2012.\n                                 of January,   of Court.\n\n        SIGNED this 9th day of July, 2026.\n\n\n\n\n                                                     ____________________________________\n                                                     ROY S. PAYNE\n                                                     UNITED STATES MAGISTRATE JUDGE\n\n\n\n\n                                                 6\n\f","ocr_status":2,"date_upload":"2026-07-10T09:10:28.251788-07:00","document_number":"121","attachment_number":null,"pacer_doc_id":"175015524109","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order AND ~Util - Set/Reset Deadlines/Hearings","acms_document_guid":""}],"date_created":"2026-07-10T07:35:33.805569-07:00","date_modified":"2026-08-26T18:56:50.153641-07:00","date_filed":"2026-07-10","time_filed":"08:43:58","entry_number":121,"recap_sequence_number":"2026-07-10.001","pacer_sequence_number":337,"description":"THIRD AMENDED DOCKET CONTROL ORDER (Markman/Claim Construction Hearing set for 4/15/2027 at 09:00 AM before Magistrate Judge Roy S. Payne., Jury Selection set for 12/6/2027 at 09:00AM before District Judge Rodney Gilstrap., Pretrial Conference set for 10/14/2027 at 09:00 AM before Magistrate Judge Roy S. Payne). Signed by Magistrate Judge Roy S. Payne on 07/09/2026. 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PATENT CASE\n  CORE SCIENTIFIC, INC. and\n                                                   JURY TRIAL DEMANDED\n  COREWEAVE, INC.,\n\n              Defendants.\n\n  CORE SCIENTIFIC, INC.,\n\n              Defendant and Third-Party\n              Plaintiff,\n\n        v.\n\n  COREWEAVE, INC.,\n\n              Third-Party Defendant.\n\n\n\n   DEFENDANT AND THIRD-PARTY DEFENDANT COREWEAVE, INC.\u2019S MOTION\n    TO DISMISS PURSUANT TO FED. R. CIV. P. 12(b)(6) AND 35 U.S.C. \u00a7 101 AND\n     JOINDER IN DEFENDANT CORE SCIENTIFIC, INC.\u2019S SECOND RENEWED\n                         MOTION TO DISMISS\n\fCase 2:25-cv-00519-JRG-RSP                      Document 115                Filed 06/24/26             Page 2 of 7 PageID #:\n                                                       3706\n\n\n\n                                               TABLE OF CONTENTS\n\n\n I.     INTRODUCTION .............................................................................................................. 1\n\n II.    STATEMENT OF THE ISSUE TO BE DECIDED ........................................................... 2\n\n III.   COREWEAVE JOINS CORE SCIENTIFIC\u2019S MOTION TO DISMISS AS TO THE\n        \u2019960, \u2019062, AND \u2019286 PATENTS ...................................................................................... 2\n\n IV.    COREWEAVE TAKES NO POSITION ON THE \u2019827, \u2019370 PATENTS, DOES NOT\n        ADDRESS THE \u2019039 PATENT HERE, AND RESERVES ALL RIGHTS...................... 2\n\n V.     CONCLUSION ................................................................................................................... 3\n\n\n\n\n                                                                  i\n\fCase 2:25-cv-00519-JRG-RSP           Document 115         Filed 06/24/26      Page 3 of 7 PageID #:\n                                            3707\n\n\n\n I.     INTRODUCTION\n\n        Plaintiffs Malikie Innovations Ltd. and Key Patent Innovations Ltd. (\u201cPlaintiffs\u201d) added\n\n CoreWeave, Inc. (\u201cCoreWeave\u201d) to this case as a co-defendant in their Second Amended\n\n Complaint (Dkt. 105) and accuse it of infringing four of the six patents asserted against the\n\n original defendant, Core Scientific, Inc. (\u201cCore Scientific\u201d). Core Scientific\u2019s Second Renewed\n\n Motion to Dismiss under Rule 12(b)(6) and 35 U.S.C. \u00a7 101, filed concurrently herewith (the\n\n \u201cCore Scientific Motion\u201d), shows that the claims of three of those patents asserted against\n\n CoreWeave\u2014U.S. Patents 7,372,960, 8,666,062, and 8,532,286 (the \u201c\u2019960, \u2019062, and \u2019286\n\n Patents\u201d)\u2014recite nothing more than patent-ineligible mathematical algorithms run on generic\n\n computers. The accused infringer\u2019s identity does not change that analysis, which the Court can\n\n decide now, on the pleadings, without discovery or claim construction.\n\n        CoreWeave therefore joins the Core Scientific Motion as to the \u2019960, \u2019062, and \u2019286\n\n Patents and respectfully asks the Court to dismiss with prejudice Plaintiffs\u2019 claims that\n\n CoreWeave infringes them.\n\n        The Core Scientific Motion does not address U.S. Patent 8,712,039 (the \u201c\u2019039 Patent\u201d)\u2014\n\n the fourth patent asserted against CoreWeave\u2014and this Motion likewise does not present\n\n argument concerning the \u2019039 Patent. CoreWeave has pled invalidity of the \u2019039 Patent, and\n\n nothing in this Motion is intended to concede or waive any argument, defense, or position as to\n\n the \u2019039 Patent. CoreWeave reserves all rights, defenses, and arguments as to that patent.\n\n Plaintiffs assert the remaining two patents, U.S. Patents 8,788,827 and 10,284,370 (the \u201c\u2019827 and\n\n \u2019370 Patents\u201d), against Core Scientific only; CoreWeave does not join the portions of the Core\n\n Scientific Motion directed to those patents and takes no position on them.\n\n\n\n\n                                                  1\n\fCase 2:25-cv-00519-JRG-RSP            Document 115        Filed 06/24/26      Page 4 of 7 PageID #:\n                                             3708\n\n\n\n II.    STATEMENT OF THE ISSUE TO BE DECIDED\n\n        Whether the claims of the \u2019960, \u2019062, and \u2019286 Patents directed to performing\n\n mathematical algorithms\u2014that may include using generic computers to perform the algorithms,\n\n and/or perform the algorithms for use in the cryptography field\u2014are directed to non-statutory\n\n subject matter and as such should be held invalid under 35 U.S.C. \u00a7 101?\n\n III.   COREWEAVE JOINS CORE SCIENTIFIC\u2019S MOTION TO DISMISS AS TO\n        THE \u2019960, \u2019062, AND \u2019286 PATENTS\n\n        Because patent eligibility turns on the asserted claims rather than the accused infringer or\n\n the infringement theory, Core Scientific\u2019s \u00a7 101 analysis applies with equal force to CoreWeave.\n\n The \u2019960 and \u2019062 Patents claim a method for finite-field calculations, and the \u2019286 Patent a\n\n method for Montgomery-style modular reduction\u2014each directed to an abstract mathematical\n\n formula at Alice step one, and each adding no inventive concept at step two beyond running the\n\n math on a generic \u201cprocessor.\u201d Alice Corp. v. CLS Bank Int\u2019l, 573 U.S. 208, 217\u201318 (2014).\n\n        CoreWeave therefore adopts and incorporates by reference Sections I, II, III.A, III.C, IV,\n\n V, VII, and VIII of the Core Scientific Motion\u2014and the authorities cited there\u2014as to the \u2019960,\n\n \u2019062, and \u2019286 Patents, and seeks the same relief: dismissal under Rule 12(b)(6).\n\n IV.    COREWEAVE TAKES NO POSITION ON THE \u2019827, \u2019370 PATENTS, DOES\n        NOT ADDRESS THE \u2019039 PATENT HERE, AND RESERVES ALL RIGHTS\n\n        CoreWeave does not join the portions of the Core Scientific Motion addressing U.S.\n\n Patent 8,788,827 and 10,284,370\u2014Sections III.B and VI\u2014and takes no position on those\n\n patents. U.S. Patent8,712,039, which is also asserted against CoreWeave but is not addressed by\n\n the Core Scientific Motion is likewise not addressed by this Motion. CoreWeave has pled\n\n invalidity of the \u2019039 Patent, and nothing here concedes or waives any issue concerning the\n\n eligibility, validity, enforceability, or infringement of the \u2019827, \u2019370, or \u2019039 Patents. CoreWeave\n\n reserves all rights, defenses, and arguments as to these patents for the appropriate time.\n\n                                                  2\n\fCase 2:25-cv-00519-JRG-RSP          Document 115         Filed 06/24/26        Page 5 of 7 PageID #:\n                                           3709\n\n\n\n V.     CONCLUSION\n\n        The Court should grant the Core Scientific Motion as to the \u2019960, \u2019062, and \u2019286 Patents\n\n and dismiss with prejudice Plaintiffs\u2019 claims that CoreWeave infringes those patents.\n\n\n\n Dated: June 24, 2026                                Respectfully submitted,\n\n                                             By: /s/ Adam J. Kessel\n                                                 Ricardo J. Bonilla\n                                                 Texas Bar No. 24082704\n                                                 rbonilla@fr.com\n                                                 FISH & RICHARDSON P.C.\n                                                 1717 Main Street, Suite 5000\n                                                 Dallas, Texas 75201\n                                                 (214) 747-5070 (Telephone)\n                                                 (214) 747-2091 (Facsimile)\n\n                                                     Eli Svetlov\n                                                     Texas Bar No. 24106483\n                                                     svetlov@fr.com\n                                                     Nicholas J. Valencia\n                                                     Texas Bar No. 24149774\n                                                     valencia@fr.com\n                                                     FISH & RICHARDSON P.C.\n                                                     909 Fannin St., Suite 2100\n                                                     Houston, Texas 77010\n                                                     (713) 654-5300 (Telephone)\n                                                     (713) 652-0109 (Facsimile)\n\n                                                     Adam J. Kessel\n                                                     Massachusetts Bar No. 661211\n                                                     kessel@fr.com\n                                                     FISH & RICHARDSON P.C.\n                                                     One Marina Park Drive\n                                                     Boston, MA 02210\n                                                     Tel: (617) 542-5070\n                                                     Fax: (617) 542-8906\n\n                                             Counsel for Defendant and Third-Party Defendant\n                                             CoreWeave, Inc.\n\n\n\n\n                                                 3\n\fCase 2:25-cv-00519-JRG-RSP               Document 115    Filed 06/24/26    Page 6 of 7 PageID #:\n                                                3710\n\n\n\n                  CERTIFICATE OF COMPLIANCE WITH THE COURT\u2019S\n                      35 U.S.C. \u00a7 101 MOTION PRACTICE ORDER\n\n\n _____ The parties agree that prior claim construction is not needed to inform the Court\u2019s\n\n analysis as to patentability.\n\n   X xThe parties disagree on whether prior claim construction is not needed to inform the\n\n Court\u2019s analysis as to patentability.\n\n                                                /s/ Adam J. Kessel\n                                                Adam J. Kessel\n\n\n\n\n                                                  4\n\fCase 2:25-cv-00519-JRG-RSP          Document 115        Filed 06/24/26     Page 7 of 7 PageID #:\n                                           3711\n\n\n\n                                CERTIFICATE OF SERVICE\n\n        I certify that a true and correct copy of the foregoing document has been served on\n\n counsel of record, who are deemed to have consented to electronic service, on June 24, 2026 via\n\n electronic filing using the Court\u2019s CM/ECF system.\n\n\n\n                                              /s/ Adam J. Kessel\n                                              Adam J. 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JURY TRIAL DEMANDED\n                                                   \u00a7\n                         Defendants.               \u00a7\n  Core Scientific, Inc.,                           \u00a7\n                                                   \u00a7\n                           Defendant and Third-    \u00a7\n                              Party Plaintiff,     \u00a7\n                                                   \u00a7\n        v.                                         \u00a7\n                                                   \u00a7\n  CoreWeave, Inc.                                  \u00a7\n                                                   \u00a7\n                           Third-Party Defendant\n                                                   \u00a7\n\n\n\n\n                DEFENDANT CORE SCIENTIFIC\u2019S MOTION TO DISMISS\n                PURSUANT TO FED. R. CIV. P. 12(b)(6) AND 35 U.S.C. \u00a7 101\n\fCase 2:25-cv-00519-JRG-RSP                      Document 114                  Filed 06/24/26               Page 2 of 39 PageID #:\n                                                       3666\n\n\n\n                                                TABLE OF CONTENTS\n\n                                                                                                                                       Page\n I.     INTRODUCTION .............................................................................................................. 1\n\n II.    STATEMENT OF ISSUES ................................................................................................ 2\n\n III.   BACKGROUND ON THE ASSERTED PATENTS ......................................................... 2\n\n        A.        Finite Field Calculation Patents (960 and 062 Patents) .......................................... 3\n\n        B.        Accelerated Verification Patents (827 and 370 Patents)......................................... 5\n\n        C.        Improved Montgomery-Style Reduction Patent (286 Patent) ................................ 6\n\n IV.    LEGAL STANDARD......................................................................................................... 7\n\n        A.        Patent Eligibility Issues Have Been Repeatedly Determined at the\n                  Motion to Dismiss Stage ......................................................................................... 7\n\n        B.        Claims Directed to Using Mathematical Calculations are Not\n                  Patent-Eligible Under Alice/Mayo .......................................................................... 8\n\n V.     THE CLAIMS OF THE 960 AND 062 PATENTS ARE PATENT\n        INELIGIBLE .................................................................................................................... 11\n\n        A.        Alice Step 1: The Claims Are Directed to the Abstract Idea of\n                  Performing Finite Field Calculations (a Mathematical Formula) ......................... 11\n\n        B.        Alice Step 2: The Claims Do Not Include an Inventive Concept ......................... 16\n\n VI.    THE CLAIMS OF THE 827 AND 370 PATENTS ARE PATENT\n        INELIGIBLE .................................................................................................................... 18\n\n        A.        Alice Step 1: The Claims Are Directed to the Abstract Idea of\n                  Generating and Verifying Public Keys in Digital Signatures (a\n                  Mathematical Formula) ......................................................................................... 18\n\n        B.        Alice Step 2: The Claims Do Not Include an Inventive Concept ......................... 22\n\n        C.        Claim 1 of the 827 Patent is Also Representative of the 370 Patent\n                  Claims ................................................................................................................... 23\n\n VII.   THE CLAIMS OF THE 286 PATENT ARE PATENT INELIGIBLE ............................ 25\n\n        A.        Alice Step 1: The Claims Are Directed to the Abstract Idea of\n                  Modular Reduction (a Mathematical Formula) .................................................... 25\n\n\n\n                                                                    i\n\fCase 2:25-cv-00519-JRG-RSP                      Document 114               Filed 06/24/26              Page 3 of 39 PageID #:\n                                                       3667\n\n\n\n         B.        Alice Step 2: The Patent Does Not Claim an Inventive Concept .......................... 28\n\n VIII.   CONCLUSION ................................................................................................................. 30\n\n\n\n\n                                                                  ii\n\fCase 2:25-cv-00519-JRG-RSP                         Document 114                Filed 06/24/26              Page 4 of 39 PageID #:\n                                                          3668\n\n\n\n                                                TABLE OF AUTHORITIES\n\n                                                                                                                                 Page(s)\n\n Cases\n\n Aatrix Software, Inc. v. Green Shades Software, Inc.,\n    890 F.3d 1354 (Fed. Cir. 2018)..................................................................................................7\n\n Affinity Labs of Texas v. DIRECTV,\n     838 F.3d 1253 (Fed. Cir. 2016)......................................................................................9, 14, 29\n\n Alice Corp. Pty. Ltd. v. CLS Bank Int\u2019l,\n     573 U.S. 208 (2014) ......................................................................................................... passim\n\n AML IP, LLC v. Bath & Body Works Direct, Inc.,\n   No. 4:22-CV-216-SDJ, 2024 WL 3825242 (E.D. Tex. Aug. 13, 2024) ....................................8\n\n Bell Atl. Corp. v. Twombly,\n     550 U.S. 544 (2007) ...................................................................................................................8\n\n In re Board of Trs. of Leland Stanford Junior Univ.,\n     989 F.3d 1367 (Fed. Cir. 2021)..............................................................................15, 16, 24, 29\n\n In re Board of Trs. of Leland Stanford Junior Univ.,\n     991 F.3d 1245 (Fed. Cir. 2021)........................................................................................ passim\n\n Broadband iTV Inc. v. Amazon.com Inc.,\n    113 F.4th 1359 (Fed. Cir. 2024) ....................................................................................9, 11, 12\n\n BSG Tech LLC v. Buyseasons, Inc.,\n    899 F.3d 1281 (Fed. Cir. 2018)................................................................................................14\n\n In re Comiskey,\n     554 F.3d 967 (Fed. Cir. 2009)..................................................................................................19\n\n Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat. Ass\u2019n,\n    776 F.3d 1343 (Fed. Cir. 2014)..................................................................................................8\n\n Customedia Techs., LLC v. Dish Network Corp.,\n    951 F.3d 1359 (Fed. Cir. 2020)..........................................................................................11, 22\n\n Diamond v. Chakrabarty,\n    447 U.S. 303, 309 (1980) ..........................................................................................................1\n\n Diamond v. Diehr,\n    450 U.S. 175 (1981) ...................................................................................................................9\n\n\n\n\n                                                                     iii\n\fCase 2:25-cv-00519-JRG-RSP                         Document 114                Filed 06/24/26             Page 5 of 39 PageID #:\n                                                          3669\n\n\n\n Digitech Image Techs., LLC v. Elecs. for Imaging, Inc.,\n    758 F.3d 1344 (Fed. Cir. 2014)....................................................................................13, 19, 20\n\n Elec. Power Grp., LLC v. Alstom S.A.,\n    830 F.3d 1350 (Fed. Cir. 2016)................................................................................9, 11, 18, 24\n\n Enfish, LLC v. Microsoft Corp.,\n    822 F.3d 1327 (Fed. Cir. 2016)................................................................................................21\n\n Ericsson Inc. v. TCL Commun. Tech. Holdings Ltd.,\n    955 F.3d 1317 (Fed. Cir. 2020)................................................................................................14\n\n First-Class Monitoring, LLC v. United Parcel Serv. of Am., Inc.,\n     389 F. Supp. 3d 456, 471 (E.D. Tex. 2019) .......................................................................17, 27\n\n Gottschalk v. Benson,\n    409 U.S. 63 (1972) .........................................................................................................9, 22, 23\n\n Intellectual Ventures I LLC v. Cap. One Bank (USA),\n     792 F.3d 1363 (Fed. Cir. 2015)................................................................................................14\n\n Intellectual Ventures I LLC v. Symantec Corp.,\n     838 F.3d 1307 (Fed. Cir. 2016)..........................................................................................13, 19\n\n Interval Licensing LLC v. AOL, Inc.,\n     896 F.3d 1335 (Fed. Cir. 2018)................................................................................................24\n\n Mackay Radio & Tel. Co. v. Radio Corp. of Am.,\n   306 U.S. 86 (1939) .....................................................................................................................9\n\n Mayo Collaborative Servs. v. Prometheus Lab\u2019ys, Inc.,\n   566 U.S. 66 (2012) ........................................................................................................... passim\n\n Optis Cellular Tech., LLC v. Apple Inc.,\n    139 F.4th 1363 (Fed. Cir. 2025) ..............................................................................10, 12, 21, 26\n\n Parker v. Flook,\n    437 U.S. 584 (1978) ......................................................................................................... passim\n\n PersonalWeb Techs. LLC v. Google LLC,\n    8 F.4th 1310 (Fed. Cir. 2021) .......................................................................................... passim\n\n SAP Am., Inc. v. InvestPic, LLC,\n    898 F.3d 1161 (Fed. Cir. 2018)........................................................................................ passim\n\n Symbology Innovations, LLC v. Dexcom, Inc.,\n    742 F. Supp. 3d 702 (E.D. Tex. 2024) .......................................................................................8\n\n\n\n\n                                                                     iv\n\fCase 2:25-cv-00519-JRG-RSP                         Document 114                 Filed 06/24/26              Page 6 of 39 PageID #:\n                                                          3670\n\n\n\n Synopsys, Inc. v. Mentor Graphics Corp.,\n    839 F.3d 1138 (Fed. Cir. 2016)....................................................................................15, 22, 27\n\n In re TLI Commc\u2019ns LLC Pat. Litig.,\n     823 F.3d 607 (Fed. Cir. 2016)........................................................................................8, 11, 30\n\n Torus Ventures LLC v. Cawley Partners, LLC,\n    No. 2:24-CV-00552-JRG, 2025 WL 1799327 (E.D. Tex. June 30, 2025) ....................8, 12, 17\n\n Waller v. Hanlon,\n    922 F.3d 590 (5th Cir. 2019) .....................................................................................................8\n\n Statutes\n\n 35 U.S.C. \u00a7 101 ...................................................................................................................... passim\n\n Other Authorities\n\n Fed. R. Civ. P. 12(b)(6)............................................................................................................1, 7, 8\n\n\n\n\n                                                                      v\n\fCase 2:25-cv-00519-JRG-RSP            Document 114         Filed 06/24/26      Page 7 of 39 PageID #:\n                                             3671\n\n\n\n        Core Scientific, Inc. (\u201cCore Scientific\u201d) moves to dismiss U.S. Patent Nos. 7,788,827 (the\n\n \u201c827 Patent\u201d), 10,284,370 (the \u201c370 Patent\u201d), 8,666,062 (the \u201c062 Patent\u201d), 7,372,960 (the \u201c960\n\n Patent\u201d), 8,532,286 (the \u201c286 Patent\u201d) from Plaintiffs\u2019 Second Amended Complaint under Fed.\n\n R. Civ. P. 12(b)(6) because claims of these asserted patents are invalid under 35 U.S.C. \u00a7 101.\n\n The asserted claims of these asserted patents are directed to performing mathematical algorithms\n\n using (at most) generic computers.1 As such, these claims are textbook examples of the kind that\n\n the Supreme Court and Federal Circuit have regularly found invalid under \u00a7 101.\n\n I.     INTRODUCTION\n\n        \u201cEinstein could not patent his celebrated law that E=mc2; nor could Newton have\n\n patented the law of gravity.\u201d Diamond v. Chakrabarty, 447 U.S. 303, 309 (1980). The mass-\n\n energy equivalence equation and the law of gravity are mathematical formulas, and mathematical\n\n formulas are not patentable. This remains the case today, even with the ubiquity of computers.\n\n        Plaintiffs Malikie Innovations Ltd. and Key Patent Innovations Ltd. (\u201cPlaintiffs\u201d)\n\n recently purchased a \u201csubstantial patent portfolio\u201d from Blackberry Ltd. Dkt. No. 105, \u00b6 1. Six of\n\n those patents are asserted here. Five out of six patents are generally directed to allegedly\n\n improved mathematical algorithms used for, e.g., cryptography functions. These five patents\n\n were filed before the Supreme Court\u2019s 2014 decision in Alice Corp. Pty. Ltd. v. CLS Bank Int\u2019l,\n\n 573 U.S. 208 (2014) fundamentally changed the patent eligibility landscape. In the years since,\n\n the Federal Circuit has repeatedly held that claims directed to the use of mathematical\n\n calculations, even if the solution is for a specific purpose in a specific field of technology, are\n\n\n\n\n 1\n   Core Scientific do not concede that U.S. Patent No. 8,712,039 (the \u201c039 Patent\u201d), included with\n Plaintiffs\u2019 Second Amended Complaint, is eligible for patenting. Core Scientific preserve all\n rights to subsequently challenge the 039 Patent\u2019s patent eligibility.\n\n\n                                                   1\n\fCase 2:25-cv-00519-JRG-RSP            Document 114        Filed 06/24/26       Page 8 of 39 PageID #:\n                                             3672\n\n\n\n invalid. See, e.g., In re Board of Trs. of Leland Stanford Junior Univ., 991 F.3d 1245, 1250-51\n\n (Fed. Cir. 2021).\n\n        That is precisely the case here. While some of the math disclosed in the patents is\n\n complex, that is not enough to save the claims from being found invalid. The mathematical\n\n algorithms and calculations claimed can be performed by humans using pencil and paper, and\n\n that some of the claims refer to \u201ccomputer-implemented methods\u201d or using \u201cprocessors\u201d to do\n\n the calculations is unquestionably insufficient as a matter of law. Alice, 573 U.S. at 223-224\n\n (rejecting the notion that \u201cgeneric computer implementations\u201d can \u201ctransform a patent-ineligible\n\n abstract idea into a patent-eligible invention\u201d). It also does not help Plaintiffs that some of the\n\n claims use the algorithms in a specific technology field, for example to verify a \u201cdigital\n\n signature\u201d used in cryptography, because \u201climiting the use of an abstract idea \u2018to a particular\n\n technological environment\u2019\u201d also cannot preserve a claim\u2019s validity. Id. at 223.\n\n        Resolving the eligibility issues here does not require discovery or claim construction and\n\n the issues are thus ripe for consideration. Core Scientific therefore respectfully requests that the\n\n Court grant its motion to dismiss the Complaint and hold all claims in the asserted patents invalid\n\n under 35 U.S.C. \u00a7 101.\n\n II.    STATEMENT OF ISSUES\n\n        Whether patent claims directed to performing mathematical algorithms\u2014that may\n\n include using generic computers to perform the algorithms, and/or perform the algorithms for use\n\n in the cryptography field\u2014are directed to non-statutory subject matter and as such should be\n\n held invalid under 35 U.S.C. \u00a7 101?\n\n III.   BACKGROUND ON THE ASSERTED PATENTS\n\n        Plaintiffs assert six patents against Core Scientific in their Second Amended Complaint:\n\n U.S. Patent Nos. 8,788,827 (the \u201c827 Patent\u201d); 10,284,370 (the \u201c370 Patent\u201d); 7,372,960 (the\n\n\n                                                   2\n\fCase 2:25-cv-00519-JRG-RSP            Document 114        Filed 06/24/26      Page 9 of 39 PageID #:\n                                             3673\n\n\n\n \u201c960 Patent\u201d); 8,666,062 (the \u201c062 Patent\u201d); 8,532,286 (the \u201c286 Patent\u201d); and U.S. 8,712,039\n\n (the \u201c039 Patent\u201d). See Dkt. No. 105, Exs. 1-6 respectively.\n\n          The 062 Patent is a continuation of the 960 Patent, and both are titled \u201cMethod and\n\n Apparatus for Performing Finite Field Calculations.\u201d See id. Exs. 3, 4. The 370 Patent is a\n\n continuation of the 827 Patent, and both are titled \u201cAccelerated Verification of Digital Signatures\n\n and Public Keys.\u201d See id. Exs. 1, 2. As such, the 960 and 062 Patents are analyzed together\n\n herein, as are the 827 and 370 Patents. The 286 Patent, is titled \u201cSystem and Method for\n\n Reducing the Computation and Storage Requirements for a Montgomery-Style Reduction.\u201d Id.,\n\n Ex. 5.\n\n          In this case, Plaintiffs assert the patents against the cryptocurrency known as \u201cBitcoin.\u201d\n\n Plaintiffs allege that Bitcoin technology uses elliptical curve cryptography (ECC) and that the\n\n asserted patents are directed to improvements in ECC technology. Dkt. No. 105, \u00b6 6. The patents\n\n are discussed in more detail next.\n\n          The remaining patent, the 039 Patent, is not subject of the instant Motion. Core Science\n\n reserves all rights, defenses, and arguments as to that patent.\n\n          A.     Finite Field Calculation Patents (960 and 062 Patents)\n\n          Public key cryptography is a cryptographic method that uses a key pair system. One key,\n\n called the public key, encrypts the data. The other key, called the private key, decrypts the data.\n\n Public key cryptography can be used in several ways to ensure confidentiality, integrity, and\n\n authenticity of digital information, including digital signatures.2 Public key cryptography has\n\n\n\n\n 2\n   See https://www.cisa.gov/news-events/news/understanding-digital-signatures. Plaintiffs cite\n this webpage in the Second Amended Complaint. Dkt. No. 105, \u00b6 12, n. 22.\n\n\n                                                   3\n\fCase 2:25-cv-00519-JRG-RSP             Document 114 Filed 06/24/26              Page 10 of 39 PageID\n                                            #: 3674\n\n\n\n been in use for decades and pre-dates the asserted patents. See, e.g., 960 Patent, 1:17-39\n\n (describing public key cryptography in the Background of the Invention).3\n\n           A form of public key cryptography known as Elliptic Curve Cryptography (ECC) also\n\n pre-dates the patents, with the 960 Patent describing ECC as \u201ca particularly efficient form of\n\n public key cryptography.\u201d Id., 1:40-43; see also Dkt. 105, \u00b6 103. Generally, as to the public and\n\n private keys, larger key sizes provide higher security levels than smaller key sizes, since the time\n\n required for an attack on the system depends on the total number of possible keys. 960 Patent,\n\n 1:66-2:2. In the context of ECC, different key sizes require different elliptic curves over different\n\n finite fields\u2014a set containing a finite number of elements where you can perform addition,\n\n subtraction, multiplication, and division (except by zero), and the results always stay within the\n\n set. In a computer, the finite field calculations are computed on machine words\u2014typically 16,\n\n 32, or 64 bit representations of numbers stored in memory. See id., 2:2-43. However, the \u201cfinite\n\n field used in ECC operations are typically 160 bits or more,\u201d and therefore they must be\n\n \u201crepresented in several machine words.\u201d Id., 2:41-43.\n\n           The 960 and 062 Patents recognized that there already existed implementations to\n\n perform operations (addition, subtraction, multiplication, division, etc.) on finite fields at the\n\n time the patents were filed. See id., 2:25-34. The programs that provided finite field calculations,\n\n however, needed to \u201cdeal with multiple machine words to complete their calculations.\u201d Id., 2:44-\n\n 46. It was therefore a goal to \u201cdetermine the number of words that must be dealt with [] in\n\n advance,\u201d such that \u201cmore efficient code can be written that expressly deals with exactly the\n\n right number of components.\u201d Id., 2:46-50. The alleged invention is directed to performing finite\n\n\n\n 3\n           Citations are to the 960 Patent for convenience. The 062 Patent has a materially identical\n     specification.\n\n\n                                                    4\n\fCase 2:25-cv-00519-JRG-RSP             Document 114 Filed 06/24/26             Page 11 of 39 PageID\n                                            #: 3675\n\n\n\n field calculations more efficiently, by representing elements in a fixed number of machine words\n\n and reusing \u201cengines\u201d (programs) and optimized multiplication and inversion methods rather\n\n than inefficiently using multiple field sizes. See id., Abstract; 4:10-26.4\n\n          As explained below, the claims of the 960 and 062 Patents are directed merely at the\n\n improved algorithms described in the specification.\n\n          B.      Accelerated Verification Patents (827 and 370 Patents)\n\n          In the Background of the Invention section of the 827 Patent, it is acknowledged that\n\n public key cryptography can provide \u201csecure communication\u201d over a data communication\n\n system \u201cwithout the necessity to transfer identical keys to other parties in the information\n\n exchange, such as a courier or the like.\u201d 827 Patent, 1:24-28.5 Public key cryptography is \u201cbased\n\n upon the generation of a key pair, one of which is private and the other public that are related by\n\n a one way mathematical function.\u201d Id., 1:28-30. Based on the \u201cunderlying mathematical\n\n structure, the public key is readily computed from the private key but the private key cannot\n\n feasibly be ascertained from the public key.\u201d Id., 1:31-34.\n\n          Historically, this has enabled users to sign and authenticate messages using the public\n\n key. Id., 1:44-48 (\u201cPublic key cryptography may also be used to digitally sign a message to\n\n authenticate the origin of the message. The author of the message signs the message using his\n\n private key and the authenticity of the message may then be verified using the corresponding\n\n public key.\u201d).\n\n\n\n\n 4\n     The \u201cengines\u201d are \u201csoftware instructions executed by the processor.\u201d See 960 Patent, 6:46-48.\n 5\n  Citations are to the 827 Patent for convenience. The 370 Patent has a materially identical\n specification.\n\n\n\n                                                    5\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26             Page 12 of 39 PageID\n                                           #: 3676\n\n\n\n        As the patents acknowledge, the \u201csecurity of such systems is dependent to a large part on\n\n the underlying mathematical structure.\u201d Id., 1:49-50. Accordingly, \u201cvarious cryptographic\n\n algorithms\u201d existed to improve security and \u201cestablish common keys for encryption and to\n\n perform digital signatures.\u201d Id., 2:22-24. \u201cSuch algorithms frequently require the verification of\n\n certain operations by comparing a pair of values as to confirm a defined relationship, referred to\n\n as the verification equality, between a set of values.\u201d Id., 2:24-27.\n\n        The patents note that one such existing algorithm to generate digital signatures is the\n\n Elliptic Curve Digital Signature Algorithm (ECDSA). Id., 2:28-30. In ECDSA, for \u201cany message\n\n M, the signer can create a signature, which is a pair of integers (r, s) in the case of ECDSA. Any\n\n verifier can take the message M, the public key Q, and the signature (r, s), and verify whether it\n\n was created by the corresponding signer. This is because creation of a valid signature (r, s) is\n\n believed to [be] possible only by an entity who know the private key d corresponding to the\n\n public key Q.\u201d Id., 2:42-48.\n\n        The patents explain while \u201cECDSA signature generation is one of the fastest digital\n\n signature generation algorithms known,\u201d id., 4:21-22, \u201cECDSA signature verification is\n\n relatively slower.\u201d Id., 4:23-24. The alleged invention is to improve ECDSA verification time, by\n\n \u201cenhanc[ing] the efficiency of performing a computation to verify that a value corresponds to the\n\n sum of two of the values.\u201d Id., 4:25-33.\n\n        As explained below, the claims of the 827 and 370 Patents are directed merely at the\n\n improved algorithms described in the specification for the more efficient computation.\n\n        C.      Improved Montgomery-Style Reduction Patent (286 Patent)\n\n        As noted previously, public key cryptography has historically been used to provide data\n\n security, integrity and authentication over data communication systems. In public key\n\n cryptography, it is often necessary to perform operations including multiplication and\n\n\n                                                   6\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 13 of 39 PageID\n                                           #: 3677\n\n\n\n exponentiation of integers, where modular arithmetic is used to operate on the integers. 286\n\n Patent, 1:20-23. A part of these operations comprises a calculation called \u201cmodular reduction.\u201d\n\n Id., 1:31-32 (\u201cModular reduction is often employed in cryptographic applications.\u201d). One of the\n\n \u201cwell-known methods for modular reduction\u201d is called \u201cMontgomery reduction.\u201d Id., 1:32-35.\n\n Montgomery reduction \u201cavoids the expensive division operations typically used in classical\n\n modular reduction. Montgomery reduction benefits from the fact that steps of multiplication and\n\n shifting are generally faster than division on most computing machines.\u201d Id., 1:35-39.\n\n Montgomery reduction also \u201crelies on performing certain precomputations and, by doing so,\n\n many calculations can be done faster.\u201d Id., 1:39-41.\n\n        The purported invention disclosed in the 286 Patent is directed to \u201cimprov[ing] the\n\n reduction efficiency of a Montgomery machine.\u201d Id., 3:21-26. The patent discloses \u201can\n\n alternative way in which to produce a Montgomery reduction\u201d by \u201cstoring a new precomputed\n\n value used to substantially replace the \u00b5 and n values used in Montgomery reduction with a\n\n single value.\u201d Id., 3:28-31. Through this modification, \u201cthe number of multiplications and\n\n registers required to effect the Montgomery reduction can be reduced.\u201d Id., 3:40-42.\n\n        As explained below, the claims of the 286 Patent are directed merely at the modified\n\n algorithm for Montgomery reduction for reducing the number of computations.\n\n IV.    LEGAL STANDARD\n\n        A.      Patent Eligibility Issues Have Been Repeatedly Determined at the Motion to\n                Dismiss Stage\n\n        \u201cIf patent eligibility is challenged in a motion to dismiss for failure to state a claim\n\n pursuant to Rule 12(b)(6), we must apply the well-settled Rule 12(b)(6) standard which is\n\n consistently applied in every area of law.\u201d Aatrix Software, Inc. v. Green Shades Software, Inc.,\n\n 890 F.3d 1354, 1357 (Fed. Cir. 2018). While well-pleaded factual allegations in the complaint are\n\n\n\n                                                   7\n\fCase 2:25-cv-00519-JRG-RSP             Document 114 Filed 06/24/26              Page 14 of 39 PageID\n                                            #: 3678\n\n\n\n generally accepted as true, no deference is given to unsupported legal conclusions. Waller v.\n\n Hanlon, 922 F.3d 590, 599 (5th Cir. 2019). Labels and conclusions are not enough, and factual\n\n allegations \u201cmust be enough to raise a right to relief above the speculative level.\u201d Bell Atl. Corp.\n\n v. Twombly, 550 U.S. 544, 555 (2007). If the allegations do not raise a claim of entitlement to\n\n relief, the complaint must be dismissed. Id. at 558.\n\n          Patent eligibility under 35 U.S.C. \u00a7 101 is a question of law, and the question has been\n\n repeatedly resolved on a Rule 12(b)(6) motion \u201cwhere the undisputed facts, considered under the\n\n standards required by that Rule, require a holding of ineligibility under the substantive standards\n\n of law.\u201d SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1166 (Fed. Cir. 2018). Such a decision\n\n focuses on the patent itself, especially the specification, without the need of \u201cextraneous fact\n\n finding outside the record.\u201d In re TLI Commc\u2019ns LLC Pat. Litig., 823 F.3d 607, 613\u201314 (Fed. Cir.\n\n 2016). Performing claim construction is not a prerequisite for determining patent eligibility.\n\n Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat. Ass\u2019n, 776 F.3d 1343, 1349\n\n (Fed. Cir. 2014). This Court and others in this District have granted motions to dismiss and/or for\n\n judgment on the pleadings when the asserted patent failed the patent eligibility test. See Torus\n\n Ventures LLC v. Cawley Partners, LLC, No. 2:24-CV-00552-JRG, 2025 WL 1799327, at *10\n\n (E.D. Tex. June 30, 2025); Symbology Innovations, LLC v. Dexcom, Inc., 742 F. Supp. 3d 702,\n\n 720 (E.D. Tex. 2024) (granting motion for judgment on the pleadings); AML IP, LLC v. Bath &\n\n Body Works Direct, Inc., No. 4:22-CV-216-SDJ, 2024 WL 3825242, at *9 (E.D. Tex. Aug. 13,\n\n 2024).\n\n          B.     Claims Directed to Using Mathematical Calculations are Not Patent-Eligible\n                 Under Alice/Mayo\n\n          Section 101 of the Patent Act lists four categories of patent eligible subject matter:\n\n \u201cprocess, machine, manufacture, or composition of matter.\u201d 35 U.S.C. \u00a7 101. The Supreme Court\n\n\n\n                                                    8\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 15 of 39 PageID\n                                           #: 3679\n\n\n\n has identified three exceptions that do not qualify as patent eligible subject matter: \u201claws of\n\n nature, natural phenomena, and abstract ideas.\u201d Diamond v. Diehr, 450 U.S. 175, 185 (1981). In\n\n Alice Corp. Pty. v. CLS Bank Int\u2019l, the Court established a two-step framework to determine\n\n whether patent claims are directed to patent-eligible subject matter. 573 U.S. 208, 217 (2014).\n\n        Alice Step One. The first step is to \u201cdetermine whether the claims at issue are directed to\n\n one of those patent-ineligible concepts,\u201d such as an abstract idea. Id. At this step, the analysis\n\n considers the \u201cfocus\u201d of the claims and their \u201ccharacter as a whole.\u201d Elec. Power Grp., LLC v.\n\n Alstom S.A., 830 F.3d 1350, 1353 (Fed. Cir. 2016) (internal quotations and citations omitted).\n\n The emphasis is on the \u201cfocus of the claimed advance over the prior art to determine if the\n\n claim\u2019s character as a whole is directed to excluded subject matter.\u201d Affinity Labs of Texas v.\n\n DIRECTV, 838 F.3d 1253, 1257 (Fed. Cir. 2016); Broadband iTV Inc. v. Amazon.com Inc., 113\n\n F.4th 1359, 1367 (Fed. Cir. 2024) (\u201cThe step one inquiry often turns to the question of what the\n\n patent asserts as the claimed advance over the prior art.\u201d).\n\n        It is a longstanding rule that \u201cmathematical algorithms for performing calculations,\n\n without more, are patent ineligible under \u00a7 101.\u201d In re Board of Trs. of Leland Stanford Junior\n\n Univ., 991 F.3d 1245, 1250 (Fed. Cir. 2021) (\u201cStanford II\u201d); see Mackay Radio & Tel. Co. v.\n\n Radio Corp. of Am., 306 U.S. 86, 94 (1939) (holding that \u201ca scientific truth, or the mathematical\n\n expression of it, is not patentable invention\u201d); Gottschalk v. Benson, 409 U.S. 63, 72 (1972)\n\n (finding claims directed to converting BCD numerals to pure binary numerals ineligible because\n\n \u201cthe patent would wholly pre-empt the mathematical formula and in practical effect would be a\n\n patent on the algorithm itself\u201d); see Mayo Collaborative Servs. v. Prometheus Lab\u2019ys, Inc., 566\n\n U.S. 66, 89 (2012) (establishing a \u201cbright-line prohibition against patenting laws of nature,\n\n mathematical formulas, and the like\u201d).\n\n\n\n\n                                                   9\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26             Page 16 of 39 PageID\n                                           #: 3680\n\n\n\n         For example, the claim in Parker v. Flook, 437 U.S. 584 (1978) was for a method of\n\n updating alarm limits in a process for catalytic chemical conversion of hydrocarbons. The\n\n method consisted of three steps: an initial step which measured the present value of a process\n\n variable, such as the current temperature; an intermediate step which applied an algorithm to\n\n calculate an updated alarm-limit value; and a final step in which the actual alarm limit was\n\n adjusted to the updated value. Id. at 586-87; see id. at 596-97 (listing claim). The Court found the\n\n claim was not patent eligible. \u201cThe process itself, not merely the mathematical algorithm, must\n\n be new and useful.\u201d Id. at 591. Notably, the \u201cnovelty of the mathematical algorithm is not a\n\n determining factor at all.\u201d Id. Applying the law to the claim, the Court found that the claimed\n\n process \u201csimply provides a new and presumably better method for calculating alarm limit\n\n values.\u201d Id. at 594\u201395. But a \u201cclaim for an improved method of calculation, even when tied to a\n\n specific end use, is unpatentable subject matter under \u00a7 101.\u201d Id. at 595 n.18; see also Optis\n\n Cellular Tech., LLC v. Apple Inc., 139 F.4th 1363, 1379 (Fed. Cir. 2025) (\u201cWe conclude that the\n\n claims are directed to an abstract idea\u2014a mathematical formula.\u201d).\n\n         Alice Step Two. If, at step one, the claims fall within one of the exceptions, the analysis\n\n moves to step two and considers the \u201celements of each claim both individually and as an ordered\n\n combination to determine whether the additional elements transform the nature of the claim into\n\n a patent-eligible application.\u201d Alice, 573 U.S. at 217. The second step focuses on searching for\n\n \u201can inventive concept\u2014i.e., an element or combination of elements that is sufficient to ensure\n\n that the patent in practice amounts to significantly more than a patent upon the ineligible concept\n\n itself.\u201d Id. at 217\u201318.\n\n         Transformation into a patent-eligible application requires \u201cmore than simply stat[ing] the\n\n [abstract idea] while adding the words \u2018apply it.\u2019\u201d Id. at 221 (citing Mayo, 566 U.S. at 72).\n\n\n\n\n                                                  10\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26             Page 17 of 39 PageID\n                                           #: 3681\n\n\n\n \u201c[W]ell-understood, routine, conventional\u201d activities normally are not sufficient to transform an\n\n abstract idea into a patent-eligible application. Mayo, 566 U.S. at 79. In the context of computer-\n\n related technology, the claim must be directed to an improvement in the functionality of the\n\n computer or network platform itself, rather than an improvement of an abstract process by\n\n invoking a computer merely as a tool. Customedia Techs., LLC v. Dish Network Corp., 951 F.3d\n\n 1359, 1364 (Fed. Cir. 2020); Alice, 573 U.S. at 223\u201326 (holding that \u201cmere recitation of a\n\n generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible\n\n invention\u201d and finding the claimed structures \u201c\u2018data processing system,\u2019 \u2018communications\n\n controller,\u2019 and \u2018data storage unit\u2019 [were] purely functional and generic\u201d); TLI, 823 F.3d at 614\n\n (holding that \u201cgeneric computer components [are] insufficient to add an inventive concept to an\n\n otherwise abstract idea\u201d).\n\n        Finally, the Federal Circuit has explained that the two Alice steps are plainly related:\n\n \u201cmany of our opinions make clear that the two stages involve overlapping scrutiny of the content\n\n of the claims\u2026.\u201d Elec. Power Group, 830 F.3d at 1353; Broadband iTV, 113 F.4th at 1369 (\u201cWe\n\n have observed that steps one and two are \u2018plainly related\u2019 and patent eligibility may \u2018involve\n\n overlapping scrutiny of the content of the claims\u2019\u2026. [I]t may be necessary to analyze\n\n conventionality at step one as well as step two, such as to determine whether a claim is directed\n\n to a longstanding or fundamental human practice or to determine what the patent asserts is the\n\n claimed advance over the prior art.\u201d).\n\n V.     THE CLAIMS OF THE 960 AND 062 PATENTS ARE PATENT INELIGIBLE\n\n        A.      Alice Step 1: The Claims Are Directed to the Abstract Idea of Performing\n                Finite Field Calculations (a Mathematical Formula)\n\n        The 960 and 062 Patents, which both issued prior to Alice, claim nothing more than the\n\n abstract idea of performing finite field calculations to obtain a reduced result. See representative\n\n\n\n                                                  11\n\fCase 2:25-cv-00519-JRG-RSP             Document 114 Filed 06/24/26             Page 18 of 39 PageID\n                                            #: 3682\n\n\n\n claim below. This is a mathematical formula like that the Federal Circuit has classified as\n\n abstract. Optis Cellular, 139 F.4th at 1379. The claims are directed to performing mathematical\n\n tasks that humans could perform using pencil and paper. See Broadband iTV, 113 F.4th at 1371\n\n (stating that the claims included steps that \u201ccan be performed in the human mind or using a\n\n pencil and paper. This is another indication that the claims are abstract.\u201d); Torus Ventures, No.\n\n 2:24-CV-00552-JRG, 2025 WL 1799327, at *6 (finding a claim was directed to the abstract idea\n\n of \u2018encrypting a bit stream of data that has already been encrypted and associated its decryption\n\n algorithm\u2019 and holding that the \u201cCourt\u2019s conclusion is further supported by the fact that the\n\n operative steps of the claim can be performed by a human with pen and paper\u201d).\n\n          Claim 3 of the 960 Patent is exemplary. It is directed to a five-step method:\n\n          3. A method of performing a finite field operation on elements of a finite field,\n                 comprising the steps of\n\n          a)      representing each element as a predetermined number of machine words;\n\n          b)      performing a non-reducing wordsized operation on said representations, said\n                  wordsized operation corresponding to said finite field operation;\n\n          c)      completing said non-reducing wordsized operation for each word of said\n                  representations to obtain an unreduced result;\n\n          d)      upon computing said unreduced result, performing a specific modular reduction\n                  of said unreduced result to reduce said unreduced result to that of a field element\n                  of said finite field to obtain a reduced result; and\n\n          e)      using said reduced result in a cryptographic operation.\n\n\n          Claim 3 is directed at a method of performing a mathematical operation, specifically a\n\n finite field operation on \u201celements\u201d to obtain a \u201creduced result.\u201d6 This is a patent-ineligible\n\n\n\n 6\n          The claim specifies that the \u201celements\u201d are represented as a predetermined number of\n     machine words. The specification states that the elements \u201cmay be represented as polynomials\n\n\n\n                                                   12\n\fCase 2:25-cv-00519-JRG-RSP             Document 114 Filed 06/24/26             Page 19 of 39 PageID\n                                            #: 3683\n\n\n\n abstract idea. See Stanford II, 991 F.3d at 1250 (finding that the claims were \u201cdirected to patent\n\n ineligible abstract ideas. Specifically, the claims are directed to the use of mathematical\n\n calculations and statistical modeling\u201d). The Federal Circuit has ruled many times that \u201c[w]ithout\n\n additional limitations, a process that employs mathematical algorithms to manipulate existing\n\n information to generate additional information is not patent eligible.\u201d Digitech Image Techs.,\n\n LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344, 1351 (Fed. Cir. 2014). That is what claim 3\n\n does\u2014it manipulates existing information (\u201celements\u201d in the form of a \u201cpredetermined number\n\n of machine words\u201d) by performing/computing certain operations to arrive at additional\n\n information (a \u201creduced result\u201d). The claimed steps can be \u201cperformed by a human, mentally or\n\n with pen and paper,\u201d demonstrating their ineligibility. Intellectual Ventures I LLC v. Symantec\n\n Corp., 838 F.3d 1307, 1318 (Fed. Cir. 2016).\n\n           In Stanford II, the Federal Circuit analyzed an analogous claim: one drawn to a\n\n \u201ccomputerized method of inferring haplotype phase in a collection of unrelated individuals\u201d that\n\n included \u201creceiving\u201d and \u201cstoring\u201d genotype data, \u201cimputing an initial haplotype phase for each\n\n individual \u2026 based on a statistical model,\u201d \u201cbuilding a data structure\u201d that included \u201cre-\n\n computation of [a] set of parameters\u201d contained within the data structure,\u201d and other calculation\n\n and storage steps. 991 F.3d at 1248. The court held that \u201cthe claims are directed to the use of\n\n mathematical calculations and statistical modeling\u201d and thus are directed to patent ineligible\n\n abstract ideas. Id. at 1250.7\n\n\n\n     with binary coefficients, which may be represented as bits in hardware or software,\u201d or simply\n     as \u201cintegers.\u201d See 960 Patent, 2:25-33. The elements therefore comprise data.\n 7\n           Indeed, the claims in Stanford II are more detailed than those here and required use of a\n     computer system with a processor and memory (see 991 F.3d at 1248), which are wholly\n     lacking from claim 3. And regardless, those generic computer components did not alter the\n     Federal Circuit\u2019s analysis or conclusion.\n\n\n                                                   13\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26             Page 20 of 39 PageID\n                                           #: 3684\n\n\n\n        The presence in claim 3 of the step of \u201cusing said reduced result in a cryptographic\n\n operation\u201d does not save the claim. \u201cAn abstract idea does not become nonabstract by limiting\n\n the invention to a particular field of use or technological environment, such as the Internet.\u201d\n\n Intellectual Ventures I LLC v. Cap. One Bank (USA), 792 F.3d 1363, 1364 (Fed. Cir. 2015). As\n\n the Federal Circuit has held, a limitation which \u201cconfine[s] the abstract idea to a particular\n\n technological environment \u2026 does not render the claims any less abstract.\u201d Affinity Labs, 838\n\n F.3d at 1258-59 (collecting cases). That applies here. Limiting the \u201creduced result\u201d generated by\n\n the mathematical calculations to use in a \u201ccryptographic operation\u201d does not transform the claim\n\n into a non-abstract idea. A \u201cclaim is not patent eligible merely because it applies an abstract idea\n\n in a narrow way.\u201d BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1287 (Fed. Cir. 2018).\n\n        In the Complaint, Plaintiffs characterize the inventions in the 960 and 062 Patents as\n\n providing \u201ctechnological benefits\u201d that result in \u201cshorter processing time and fewer processor\n\n operations.\u201d Dkt. No. 105, \u00b6\u00b6 110-11; see also 960 Patent, 4:24-26 (\u201cIn this way, fast engines can\n\n be produced for many specific finite fields, without duplicating the bulk of the engine\n\n instructions (program).\u201d).\n\n        Even taking those representations as true, it does not impact the analysis. First, the claim\n\n does not require \u201cfast engines\u201d or \u201cmany specific finite fields.\u201d See Ericsson Inc. v. TCL\n\n Commun. Tech. Holdings Ltd., 955 F.3d 1317, 1328-29 (Fed. Cir. 2020) (holding that details\n\n from the specification cannot be imported into the claims when considering the abstract idea\n\n analysis: \u201cthis allegedly novel aspect of the invention is wholly missing\u201d from the claims). As\n\n noted above, claim 3 is so broad as to be capable of being performed with pencil and paper.\n\n        Further, even if the claimed invention results in an improved way to perform finite field\n\n operations, that is not enough to impart eligibility. \u201cEven accepting the argument that the claimed\n\n\n\n\n                                                  14\n\fCase 2:25-cv-00519-JRG-RSP              Document 114 Filed 06/24/26             Page 21 of 39 PageID\n                                             #: 3685\n\n\n\n process results in improved data, we are not persuaded that claim 1 is not directed to an abstract\n\n mathematical calculation.\u201d In re Board of Trs. of Leland Stanford Junior Univ., 989 F.3d 1367,\n\n 1373 (Fed. Cir. 2021) (\u201cStanford I\u201d); see Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d\n\n 1138, 1151 (Fed. Cir. 2016) (\u201c[A] claim for a new abstract idea is still an abstract idea.\u201d).\n\n           Claim 3 is therefore directed to an abstract idea. The same analysis applies to the other\n\n claims in the 960 and 062 Patents. As to the 960 Patent, each of the other independent claims (1,\n\n 2, 4, 5) applies some subset of the same steps of using a machine word representation,\n\n performing finite field operations on the words and performing a reduction on the words to\n\n obtain a reduced result. See claim 1 (\u201creduced result\u201d); claim 2 (\u201creduce said unreduced\n\n intermediate product to that of a field element\u201d); claim 4 (same); claim 5 (\u201cobtain a reduced\n\n result\u201d). While exemplary claim 3 outlines the operation for a general finite field operation,\n\n claims 1 and 2 describe addition and multiplication respectively, which are still mathematical\n\n computations that can be performed by humans. Claim 4 is an even more generalized version,\n\n utilizing subsets rather than words computed by a processor. Claim 5 adds that the finite fields\n\n are paired with elliptic curves. Every claim is directed to performing mathematical calculations,\n\n which are abstract ideas.8\n\n           The dependent claims likewise add nothing other than further details of the mathematical\n\n formula. They specify that the modular reduction \u201cis determined by said finite field\u201d (claim 6),\n\n\n\n\n 8\n            To the extent the claims include an \u201cengine\u201d (claim 4) or \u201cfinite field multipliers\u201d and\n     \u201cfinite field reducer[s]\u201d (claim 2), these are the names for the generic processors or programs\n     (source code) used to carry out the mathematical calculations. See 960 Patent, 2:37-46\n     (describing \u201ca general purpose computational engine (for example a typical CPU)\u201d and\n     (\u201c[e]ngine routines (programs)\u201d); 4:12-26; 6:45-48 (\u201cThe processor [] operates to execute an\n     appropriate engine \u2026 on the data. The engines may be software instructions executed by the\n     processor, or they may have dedicated coprocessors.\u201d).\n\n\n                                                    15\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 22 of 39 PageID\n                                           #: 3686\n\n\n\n the finite field operation is addition (claim 7), subtraction (claim 8) or multiplication (claim 9).\n\n These merely specify the type of math performed, and do not make the claims any less abstract.\n\n        As to the 062 Patent, claim 1 closely tracks claim 3 of the 960 Patent, only specifying\n\n that the method is performed by \u201ca processor.\u201d This recitation of using a generic processor to\n\n perform the algorithm does not alter the analysis. See, e.g., Stanford I, 989 F.3d at 1372 (finding\n\n that claims requiring \u201cusing a computer system comprising a processor and memory\u201d to perform\n\n mathematical operations were patent ineligible). Independent claim 8 is directed to a \u201cnon-\n\n transitory computer readable medium comprising computer executable instructions for\n\n performing a finite field operation,\u201d and independent claim 15 similarly is directed to a\n\n \u201ccryptographic engine comprising a processor and memory \u2026 comprising instructions.\u201d\n\n Otherwise, both claims likewise track claim 3 of the 960 Patent. The dependent claims of the 062\n\n Patent add further details regarding the mathematical calculations performed. These limitations\n\n are not significantly more than the abstract idea identified in the 960 Patent, claim 3.\n\n        B.      Alice Step 2: The Claims Do Not Include an Inventive Concept\n\n        Turning to the second step of the Alice test, the Court considers the limitations of the\n\n claims, other than the abstract idea, to determine whether they contain an \u201cinventive concept\u201d\n\n sufficient to transform the abstract idea into a patent-eligible application. Alice, 573 U.S. at 217.\n\n As discussed above, representative claim 3 of the 960 Patent recites a five-step method: (1) a\n\n representation as \u201ca predetermined number of machine words\u201d; (2) performing a non-reducing\n\n finite field operation on said representation; (3) completing the operation for each word; (4)\n\n performing modular reduction to obtain a reduced result; and (5) using the result in a\n\n cryptographic operation. There is nothing in the claim other than the steps of the mathematical\n\n algorithm. As such, the claim fails Alice step two because the limitations \u201cadd nothing outside\n\n the abstract realm.\u201d SAP, 898 F.3d at 1169.\n\n\n                                                   16\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26               Page 23 of 39 PageID\n                                           #: 3687\n\n\n\n        Limiting the claim to using the reduced result \u201cin a cryptographic operation\u201d does not\n\n change the analysis. The Supreme Court in Alice made it clear that simply adding \u201capply it\u201d to an\n\n abstract idea does not transform the claim into a patent eligible application. 573 U.S. at 221.\n\n Here, the 960 Patent admits that finite field operations were used in cryptographic operations\n\n before the alleged invention. 960 Patent, 1:45-2:26. Thus, there is nothing \u201csignificantly more\u201d\n\n in the claims beyond the abstract idea itself. See First-Class Monitoring, LLC v. United Parcel\n\n Serv. of Am., Inc., 389 F. Supp. 3d 456, 471 (E.D. Tex. 2019) (Bryson, J., sitting by designation)\n\n (\u201cThat is, the assertedly \u2018inventive concept\u2019 is the abstract idea itself. As noted, however, the\n\n \u2018inventive concept\u2019 element of the section 101 analysis requires \u2018significantly more\u2019 than the\n\n abstract idea itself.\u201d). It does not matter whether the mathematical calculations in the claim\n\n improve on what existed previously (a point which Core Scientific do not concede). See Torus\n\n Ventures, No. 2:24-CV-00552-JRG, 2025 WL 1799327, at *10 (\u201cEven if the Court were to accept\n\n [patentee\u2019s] view that these particular ideas are not well-known, routine, or conventional, the\n\n Court would still be compelled to find that a \u2018claim for a new abstract idea is still an abstract\n\n idea.\u2019\u201d) (citing PersonalWeb Techs. LLC v. Google LLC, 8 F.4th 1310, 1318 (Fed. Cir. 2021)).9\n\n        Claim 3 therefore fails both parts of the Alice test and should be found invalid under \u00a7\n\n 101.\n\n        The analysis of Alice Step 2 is the same for the other claims of the 960 and 062 Patents.\n\n Some independent claims recite \u201ca processor\u201d (960, claims 2, 4, 5), \u201can accumulator\u201d and\n\n \u201cregisters\u201d (960, claim 1), and \u201cprocessor and memory\u201d (062, claim 15). However, as the Federal\n\n Circuit in SAP found, \u201c[s]ome of the claims require various databases and processors, which are\n\n\n\n 9\n        The Supreme Court has held that the \u201cnovelty of the mathematical algorithm is not a\n determining factor at all\u2026. [I]t is treated as though it were a familiar part of the prior art.\u201d Flook,\n 437 U.S. at 591.\n\n                                                   17\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26               Page 24 of 39 PageID\n                                           #: 3688\n\n\n\n in the physical realm of things. But it is clear, from the claims themselves and the specification,\n\n that these limitations require no improved computer resources [the patent owner] claims to have\n\n invented, just already available computers, with their already available basic functions, to use as\n\n tools in executing the claimed process.\u201d 898 F.3d at 1169\u201370. The 960 Patent does not disclose\n\n any specific improvements to the processer, accumulator, or registers themselves, but, as\n\n illustrated above, is directed to more efficient finite field calculations, which are purely\n\n mathematical in nature. Therefore, \u201csuch invocations of computers and networks that are not\n\n even arguably inventive are insufficient to pass the test of an inventive concept in the application\n\n of an abstract idea.\u201d Elec. Power Grp., 830 F.3d at 1355; PersonalWeb, 8 F.4th at 1319\n\n (\u201c[M]erely adding computer functionality to increase the speed or efficiency of the process does\n\n not confer patent eligibility on an otherwise abstract idea.\u201d).\n\n        Accordingly, the claims of the 960 and 062 Patent do not qualify for patent protection,\n\n and as such should be found invalid under \u00a7 101.\n\n VI.    THE CLAIMS OF THE 827 AND 370 PATENTS ARE PATENT INELIGIBLE\n\n        A.      Alice Step 1: The Claims Are Directed to the Abstract Idea of Generating\n                and Verifying Public Keys in Digital Signatures (a Mathematical Formula)\n\n        The 827 and 370 Patents claim nothing more than the abstract idea of recovering a public\n\n key from a signature\u2014a mathematical formula that humans could perform with pencil and paper\n\n which is merely sped up by a computer.\n\n        The patents describe the invention as \u201cverifying the equality of a relationship between the\n\n sum of scalar multiples of a pair of points on an elliptic curve and a third point on said curve.\u201d\n\n 827 Patent, 4:38-40. The patent explains, \u201cthere is a need to enhance the efficiency of performing\n\n a computation to verify that a value corresponds to the sum of two of the values [and it is] an\n\n object of the presentation invention to obviate or mitigate the [current] disadvantages.\u201d Id., 4:28-\n\n\n\n                                                   18\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26             Page 25 of 39 PageID\n                                           #: 3689\n\n\n\n 32. The method comprises three steps: (1) \u201cobtaining a pair of integers\u201d related by one of several\n\n scalars; (2) obtaining an equivalent relationship between the integers from the relationship\n\n between the scalars (3) computing the relationship to verify the equality. Id., 4:40-47. Claim 1 of\n\n the 827 Patent recites \u201c[a] computer-implemented method\u201d performing these steps:\n\n        1. A computer-implemented method comprising:\n\n        receiving, from a signer, a signature on a message M, wherein the signature\n                includes a first signature component r and a second signature component\n                s;\n\n        obtaining an elliptic curve point associated with the first signature component r;\n               and\n\n        generating, by operation of a cryptographic module comprising one or more\n               processors, a public key of the signer based on the elliptic curve point and\n               a hash value e computed from the message M:\n\n        wherein the elliptic curve point comprises a first elliptic curve point R, the public\n               key of the signer comprises a second elliptic curve point Q, generating the\n               public key of the signer comprises computing Q=r-1 (sR-eG), and G\n               comprises a generator of an elliptic curve group that includes the first\n               elliptic curve point R and the second elliptic curve point Q.\n\n        The three steps in claim 1 are performed within the \u201ccontext of an algorithm such as the\n\n ECDSA.\u201d Id., 4:63.\n\n        Claim 1 is therefore directed to the abstract idea of performing mathematical calculations\n\n to generate a public key of a signer\u2014a mathematical formula. With the \u201cexception of generic\n\n computer-implemented steps, there is nothing in the claims themselves that foreclose them from\n\n being performed by a human.\u201d Symantec, 838 F.3d at 1318; see In re Comiskey, 554 F.3d 967,\n\n 979 (Fed. Cir. 2009) (holding that \u201cmental processes\u2014or processes of human thinking\u2014standing\n\n alone are not patentable even if they have practical application.\u201d). Further, as with analysis of the\n\n 960 and 062 Patents above, using mathematical algorithms on existing information to generate\n\n additional information is not patent eligible. Digitech, 758 F.3d at 1351. In Digitech, the claim\n\n\n\n                                                  19\n\fCase 2:25-cv-00519-JRG-RSP           Document 114 Filed 06/24/26              Page 26 of 39 PageID\n                                          #: 3690\n\n\n\n recited a \u201cprocess of taking two data sets and combining them into a single data set, the device\n\n profile. The two data sets are generated by taking existing information...and organizing this\n\n information into a new form.\u201d Id. The Federal Circuit held that such a \u201cclaim thus recites an\n\n ineligible abstract process of gathering and combining data that does not require input from a\n\n physical device.\u201d Id. Similarly, claim 1 of the 827 Patent merely recites a method of calculating\n\n the public key from existing information (the signature components). Therefore, claim 1 is also\n\n directed to an abstract idea.\n\n        Claim 1 is much like the claim the Supreme Court found invalid in Parker v. Flook. That\n\n claim is reproduced below:\n\n               1. A method for updating the value of at least one alarm limit on at least\n        one process variable involved in a process comprising the catalytic chemical\n        conversion of hydrocarbons wherein said alarm limit has a current value of\n\n                Bo+K\n\n               wherein Bo is the current alarm base and K is a predetermined alarm offset\n        which comprises:\n\n               (1) Determining the present value of said process variable, said present\n        value being defined as PVL;\n\n                Determining a new alarm base B1, using the following equation:\n\n                B[1]=Bo(1.0<v1>minF)+PVL(F)\n\n                where F is a predetermined number greater than zero and less than 1.0;\n\n                (3) Determining an updated alarm limit which is defined as B1+GK; and\n        thereafter\n\n                (4) Adjusting said alarm limit to said updated alarm limit value.\n\n\n        The Court found this claim invalid: \u201cif a claim is directed essentially to a method of\n\n calculating, using a mathematical formula, even if the solution is for a specific purpose, the\n\n\n\n\n                                                 20\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 27 of 39 PageID\n                                           #: 3691\n\n\n\n claimed method is nonstatutory.\u201d Flook, 437 U.S. at 595 (emphasis added). Claim 1 of the 827\n\n Patent is also nonstatutory, because it is directed to using the mathematical formula Q=r-1(sR-eG)\n\n from existing information (a signature) to generate additional information (a public key).10 That it\n\n may do so to generate a public key is of no moment because using the algorithm for a \u201cspecific\n\n purpose\u201d is not enough. Id.; see also Stanford II, 991 F.3d at 1250.\n\n        That claim 1 requires a \u201ccomputer-implemented\u201d method and has \u201ca plurality of\n\n processors\u201d does not change the analysis. \u201c[I]mplementing and processing calculations with a\n\n regular computer does not change the character of [the] claim \u2026 from an abstract idea into a\n\n practical application.\u201d Id.11 Indeed, claim 1 does not recite any \u201cspecific improvement to the way\n\n computers operate.\u201d Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1336 (Fed. Cir. 2016). It\n\n simply describes steps or operations to be performed\u2014i.e., \u201creceiving,\u201d \u201cobtaining,\u201d\n\n \u201cgenerating,\u201d \u201ccomputing\u201d\u2014and the relationships between mathematical objects\u2014i.e., \u201celliptic\n\n curve points,\u201d \u201csignature component[s],\u201d and \u201chash values.\u201d\n\n        Plaintiffs again allege that the 827 and 370 Patents provide a \u201ctechnological\n\n improvement\u201d to the ECDSA digital signature verification process by enabling \u201caccelerated\n\n signature verification.\u201d Dkt. 105, \u00b6 74. Similarly, the specification alleges that \u201cthe efficiency of\n\n verifying of ECDSA signatures is particularly desirable\u201d and it is an \u201cobject of the present\n\n invention to obviate or mitigate\u201d disadvantages with current methods. 827 Patent, 4:18-19, 4:30-\n\n 32). But the claims do not specify any improved speed or efficiency. At any rate, any \u201cimproved\n\n\n 10\n         Claim 1 is also much like the one the Federal Circuit found was directed to an abstract\n idea (a mathematical formula) in Optis Cellular. See 139 F.4th at 1378.\n\n 11\n        In Flook, the Supreme Court recognized that the claim was intended to be performed\n  through \u201cthe use of computers,\u201d but that did not change the analysis. 437 U.S. at 595.\n\n\n\n                                                  21\n\fCase 2:25-cv-00519-JRG-RSP             Document 114 Filed 06/24/26              Page 28 of 39 PageID\n                                            #: 3692\n\n\n\n speed or efficiency inherent with applying the abstract idea on a computer\u201d is not enough under\n\n Alice Step One. Customedia, 951 F.3d at 1364; PersonalWeb, 8 F.4th at 1319. And as already\n\n explained, even assuming that the underlying mathematical algorithm specified in the claims\n\n may be an improvement over earlier iterations, a \u201cclaim for a new abstract idea is still an abstract\n\n idea.\u201d Synopsys, 839 F.3d at 1151. Thus, claim 1 is directed to an abstract idea.\n\n        Claim 1 is representative of the other 827 Patent claims. Independent claim 6 simply adds\n\n that the steps are \u201cexecuted by one or more processors.\u201d Independent claim 10 requires \u201c[a]\n\n computing device\u201d that performs the steps. The dependent claims add nothing of significance.\n\n They require verifying the generated key represents the public key (claim 2, 7, 11), adding a\n\n cofactor to the first elliptic curve point (claim 3, 8, 12), stating the public key can be used to\n\n verify the signature (claim 4, 9, 13), and verifying the signature according to an ECDSA (claim\n\n 5). These limitations, directed to further details of the algorithm or to the field of use, do not\n\n make the claims any less abstract and confirm that claim 1 is representative.\n\n        B.      Alice Step 2: The Claims Do Not Include an Inventive Concept\n\n        The claims also fail Alice step two because there is nothing else in the claim transforming\n\n the claim into a patent eligible application. As before, aside from the generic \u201cone or more\n\n processors,\u201d there is nothing in the claim other than the citation of the steps of the mathematical\n\n algorithm. The claim therefore fails Alice step two because the limitations \u201cadd nothing outside\n\n the abstract realm.\u201d SAP, 898 F.3d at 1169; PersonalWeb, 8 F.4th at 1319 (find that \u201cthere is\n\n nothing \u2018inventive\u2019 about any claim details, individually or in combination, that are not\n\n themselves abstract ideas\u201d). In Benson, the claim was directed to converting one form of\n\n numerical representation to another and the patent applicant invoked a \u201cgeneral-purpose digital\n\n computer\u201d to carry out the task. 409 U.S. at 65. But the computer implementation did not provide\n\n the necessary inventive concept as the Supreme Court held that \u201cmathematical procedures can be\n\n\n                                                   22\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26               Page 29 of 39 PageID\n                                           #: 3693\n\n\n\n carried out in existing computers long in use, no new machinery being necessary.\u201d Id. at 67; see\n\n Mayo, 566 U.S. at 84 (\u201csimply implementing a mathematical principle on a physical machine,\n\n namely a computer, was not a patentable application of that principle.\u201d).\n\n        The dependent claims also do not add \u201csignificantly more\u201d to the abstract idea.\n\n Integrating more elliptic curves, using cofactors, and verifying signatures of the message\n\n according to an ECDSA are merely further details in the algorithm and/or are not new features.\n\n 827 Patent, claims 3, 8, 12 (\u201cthe first elliptic curve point R is generated based on the first\n\n signature component r and a cofactor h for an elliptic curve\u201d); claims 2, 7, 11 (\u201cverifying that the\n\n second elliptic curve point Q represents the public key of the signer\u201d); claims 4, 9, 13 (\u201cthe\n\n public key of the signer can be used to verify the signature\u201d); claim 5 (\u201cverifying the signature\n\n comprises verifying the signature according to an Elliptic Curve Digital Signature Algorithm\n\n (ECDSA)\u201d). See, e.g., 827 Patent, 2:28-41-63. Thus, the claims are all invalid.\n\n        C.      Claim 1 of the 827 Patent is Also Representative of the 370 Patent Claims\n\n        The claims in the 370 Patent include 3 independent claims and 8 dependent claims.\n\n Claim 1 of the 370 Patent is like claim 1 of the 827 Patent:\n\n        1. A method performed by a hardware processor of a computing device,\n        comprising:\n\n        receiving, by a receiver of the computing device and through a network, an\n        electronic message including a signature, wherein the electronic message omits a\n        public key of a signer, and the signature comprises a signature on the electronic\n        message M;\n\n        receiving, by the receiver of the computing device and through the network, a first\n        elliptic curve point associated with a signature component from the signer,\n        wherein the signature component comprises a first signature component r, the\n        signature includes the first signature component r and a second signature\n        component s, and the first elliptic curve point comprises an elliptic curve point R;\n\n        recovering, by the hardware processor of the computing device, the omitted\n        public key of the signer based on the received first elliptic curve point and the\n        received signature, wherein the public key comprises a second elliptic curve point\n\n\n                                                   23\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 30 of 39 PageID\n                                           #: 3694\n\n\n\n        in an elliptic curve group different from the first elliptic curve point, wherein the\n        elliptic curve group includes the first and second elliptic curve points, wherein the\n        second elliptic curve point comprises an elliptic curve point Q, wherein\n        recovering the omitted public key of the signer comprises computing Q=r\u22121\n        (sR\u2212eG), wherein G comprises a generator of an elliptic curve group that includes\n        the elliptic curve point R and the elliptic curve point Q, and wherein e is a hash\n        value computed from the electronic message M; and\n\n        verifying, by the hardware processor of the computing device, the received\n        signature using the recovered public key which provides an accelerated\n        verification of the received signature.\n\n        Claim 1 thus recites materially the same steps of 827 Patent claim 1, and adds the\n\n limitation of using the public key for verification. But this latter step is acknowledged to have\n\n been routine in cryptography. 370 Patent, 2:32-45; 3:1-9. Thus, it does not change the analysis\n\n concerning whether the claim is directed to an abstract idea.\n\n        Claim 1 also specifies generic computing components (\u201ccomputing device,\u201d \u201chardware\n\n processor,\u201d \u201cnetwork\u201d). It is beyond debate that such limitations cannot convert an abstract claim\n\n into a non-abstract one. Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1345 (Fed. Cir.\n\n 2018) (finding claims abstract when they offer \u201cnothing more than generic, pre-existing\n\n computer functionality\u201d to perform the abstract idea).\n\n        Nor do these generic limitations save the claim under Alice Step Two. See Elec. Power\n\n Grp., 830 F.3d at 1355 (\u201cThe claims at issue do not require any nonconventional computer,\n\n network, or display components, or even a \u2018non-conventional and non-generic arrangement of\n\n known, conventional pieces,\u2019 but merely call for performance of the claimed information\n\n collection, analysis, and display functions \u2018on a set of generic computer components\u2019\u2026.\u201d)\n\n (citations omitted); Stanford I, 989 F.3d at 1374 (stating that \u201cit is hard to imagine a patent claim\n\n that recites hardware limitations in more generic terms than the terms employed by claim 1\n\n [\u2018computer with a \u2018processor\u2019 and a \u2018memory\u2019); see also Alice, 573 U.S. at 226 (explaining that\n\n\n\n\n                                                  24\n\fCase 2:25-cv-00519-JRG-RSP              Document 114 Filed 06/24/26              Page 31 of 39 PageID\n                                             #: 3695\n\n\n\n the hardware-related terms \u2018data processing system,\u2019 \u2018communications controller,\u2019 and \u2018data\n\n storage unit\u2019 are \u2018purely functional and generic\u2019)\u201d).\n\n           Thus, claim 1 of the 370 Patent is also invalid for failing to claim patent-eligible subject\n\n matter.\n\n           The remaining independent claims (6 and 10) recite the same steps as claim 1, but in the\n\n context of (1) a non-transitory computer readable medium and processors (claim 6) and (2) a\n\n computing device (claim 10). As with claim 1, these limitations do not change the analysis as a\n\n \u201cmere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a\n\n patent-eligible invention.\u201d Alice, 573 U.S. at 223.\n\n           The dependent claims of the 370 Patent match those of the 287 Patent: verifying that Q is\n\n the public key (claims 2, 7, 11), the elliptic curve point R generated based on r and a cofactor h\n\n (claims 3, 8), use of public key in signature verification (claims 4, 9), and the verification based\n\n on ECDSA (claim 5). See Section VI.B supra. Therefore, claim 1 of the 370 Patent is\n\n representative of all claims in the patent, and as claim 1 fails the two-step test under Alice, all\n\n claims in the 370 Patent should be held invalid under 35 U.S.C. \u00a7 101.\n\n VII.      THE CLAIMS OF THE 286 PATENT ARE PATENT INELIGIBLE\n\n           A.     Alice Step 1: The Claims Are Directed to the Abstract Idea of Modular\n                  Reduction (a Mathematical Formula)\n\n           The 286 Patent is based around the well-known Montgomery-style reduction and\n\n discloses an alleged improved method of Montgomery-style reduction based on a precomputed\n\n value. 286 Patent, 1:32-35 (\u201cOf the well known method for modular reduction, the most\n\n commonly used is the method of Montgomery modular reduction, referred to as Montgomery\n\n reduction in short\u201d). Representative claim 1 recites a 3-step process: (1) obtaining an operand;\n\n (2) computing a new operand using a reduction value; (3) outputting the new operand:\n\n\n\n                                                    25\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26             Page 32 of 39 PageID\n                                           #: 3696\n\n\n\n        1. A method for performing, on a cryptographic apparatus, a Montgomery-style\n        reduction in a cryptographic operation, the method comprising:\n        obtaining an operand for the cryptographic operation;\n\n        computing a modified operand using a reduction value, instead of a modulus\n        used in performing a standard Montgomery reduction, to perform a replacement\n        of a least significant word of the operand, rather than perform a cancellation\n        thereof, the reduction value being a function of the modulus; and\n\n        outputting the modified operand.\n\n        Claim 1 is directed to an abstract idea of using a mathematical algorithm (formula) to\n\n perform a form of Montgomery reduction. It is acknowledged in the patent that \u201cmodular\n\n arithmetic is used to operate on the integers\u201d in cryptography and one classical example is \u201cto\n\n multiply two numbers modulo n.\u201d 286 Patent, 1:20-30. The approach to this calculation is \u201cto\n\n first perform the multiplication and then calculate the remainder...The calculation of the\n\n remainder is referred to as reduction in modular arithmetic.\u201d Id. Montgomery reduction was one\n\n of the most used methods for modular reduction. Id., 1:31-46. As such, a form of Montgomery\n\n style reduction is an abstract idea. See Mayo, 566 U.S. at 89 (holding there is \u201ca bright-line\n\n prohibition against patenting laws of nature, mathematical formulas, and the like\u201d); Flook, 437\n\n U.S. at 591 (holding that \u201cthe process itself, not merely the mathematical algorithm, must be new\n\n and useful\u201d); SAP, 898 F.3d at 1167 (analyzing information by mathematical algorithms without\n\n more is directed to an abstract idea); Optis Cellular, 139 F.4th at 1379 (\u201cWe conclude that the\n\n claims are directed to an abstract idea\u2014a mathematical formula.\u201d).\n\n        Applying the Montogomery reduction on a \u201ccryptographic apparatus\u201d or as part of a\n\n \u201ccryptographic operation\u201d does not make the abstract idea any less abstract. First, Montogomery\n\n reduction was a well-understood technique used in cryptography before the patent. 286 Patent,\n\n 1:31-46. The patent confirms that a \u201ccryptographic apparatus\u201d is generic hardware and/or\n\n software. 286 Patent, 4:2-5 (\u201cIt will be appreciated that the cryptographic module [] and any\n\n\n\n                                                  26\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 33 of 39 PageID\n                                           #: 3697\n\n\n\n component thereof may be implemented as an apparatus in hardware or in software (computer\n\n readable instructions embodied in/on a computer readable medium.\u201d). Second, \u201ca claim for an\n\n improved method of calculation, even when tied to a specific end use, is unpatentable subject\n\n matter under \u00a7 101.\u201d Flook, 437 U.S. at 595 n.18\n\n        Plaintiffs again allege in the Complaint that the 286 Patent provides solutions to\n\n \u201ctechnological problems.\u201d Dkt. No. 105, \u00b6 122. But the alleged improvements are to the\n\n Montgomery reduction algorithm itself, which is not enough to overcome Alice Step One. Even\n\n assuming arguendo the proposed method in the patent yields a more efficient Montgomery\n\n reduction by reducing the number of multiplications and registers previously needed, the\n\n \u201cimprovement in computational accuracy alleged here does not qualify as an improvement to a\n\n technological process; rather, it is merely an enhancement to the abstract mathematical\n\n calculation of haplotype phase itself.\u201d Stanford II, 991 F.3d at 1251; see also First-Class\n\n Monitoring, 389 F. Supp.3d at 462 (\u201cNor does the fact that a computer can perform such\n\n operations more rapidly and efficiently make an abstract idea any less abstract or any more\n\n patent-eligible.\u201d) (collecting cases). That applies here. An improved Montgomery reduction\n\n algorithm that performs calculations more efficiently is still an algorithm and thus an abstract\n\n idea. See 286 Patent, 3:21-22 (stating that the objective of the invention is \u201cto improve the\n\n reduction efficiency of a Montgomery machine\u201d). Therefore, the improvements here are\n\n enhancements to the ineligible concept and are not eligible for patent protection. See Synopsys,\n\n 839 F.3d at 1151 (\u201c[A] claim for a new abstract idea is still an abstract idea\u201d).12\n\n\n\n 12\n        None of the 286 Patent claims refer to a reduction in the number of registers needed. The\n  only claims that specify registers are dependent claims 4, 13, and 21. But those claims only add\n  details regarding performing a \u201cstandard Montgomery reduction,\u201d which was admittedly in the\n  prior art. 286 Patent, 1:31-34 (\u201cModular reduction is often employed in cryptographic\n\n\n\n                                                  27\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 34 of 39 PageID\n                                           #: 3698\n\n\n\n        Claim 1 is representative of the remaining claims. The other independent claims (10, 18)\n\n are materially identical to claim 1, specifying only \u201ccomputer executable instructions \u2026\n\n executed by [a] processor\u201d (claim 10) or \u201ccomputer executable instructions\u201d on a \u201cnon-transitory\n\n computer readable medium\u201d (claim 18). The three algorithmic steps in both claims are otherwise\n\n materially identical to the ones in claim 1. The dependent claims add nothing more than\n\n additional details to the algorithm: providing the equation of n\u2019 (claims 2, 11, 19), further\n\n replacing words of the operand using a reduction value (claims 3, 12, 20), discussing the steps of\n\n a standard Montgomery reduction (claims 4, 13, 21), use of a Montgomery engine (claim 5),13\n\n identifying that the reduction value is pre-computed (claims 6, 14, 22), shifting words of the\n\n operand (claims 7, 15, 23), adding a carry to the output if a carry is produced (claims 8, 16, 24),\n\n and listing multiplication or squaring as cryptographic operation (claims 9, 17, 25). These\n\n limitations are directed at additional steps or details of the method Montgomery reduction, do not\n\n make the claims any less abstract, and confirm that claim 1 is representative.\n\n        B.      Alice Step 2: The Patent Does Not Claim an Inventive Concept\n\n        Claim 1 also fails Alice step 2. At this step, the analysis focuses on limitations of the\n\n claim both individually and combined to determine whether the additional limitations transform\n\n the claim into a patent-eligible application. Alice, 573 U.S. at 217. Here, the entirety of the claim\n\n is directed at the allegedly improved Montgomery reduction algorithm. The recited steps are (1)\n\n\n\n  applications. Of the well known methods for modular reduction, the most commonly used is the\n  method of Montgomery modular reduction, referred to as Montgomery reduction in short.\u201d).\n 13\n         The \u201cMontgomery engine\u201d is generic hardware or software configured to perform the\n algorithm and was admitted prior art in the 286 Patent. See 286 Patent, 1:65-2:3 (\u201c[A]\n computational engine may be used for calculating the Montgomery product of two numbers, this\n engine being sometimes referred to as a Montgomery engine or Montgomery machine. The\n engine may be implemented in a hardware or software module and operates on a set of\n parameters to produce a result.\u201d); id., 4:2-5.\n\n\n                                                  28\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 35 of 39 PageID\n                                           #: 3699\n\n\n\n obtaining data (an \u201coperand\u201d); (2) modifying data with the mathematical algorithm (\u201ccomputing\n\n a modified operand\u201d); and (3) outputting data (\u201cthe modified operand\u201d). See Stanford I, 989 F.3d\n\n at 1374 (finding claim failed Alice step 2: \u201cclaim 1 ends at storing the haplotype phase and\n\n \u2018providing\u2019 it \u2018in response to a request.\u2019 Simply storing information and providing it upon request\n\n does not alone transform the abstract idea into patent eligible subject matter.\u201d). This is not\n\n materially different from claim 1\u2019s steps of modifying and outputting data. Even if the claim\n\n captures improvements in the Montgomery reduction algorithm (which Core Scientific do not\n\n concede), the fact that \u201csome of those [claimed] steps had not previously been employed in the\n\n art was not sufficient, standing alone, \u2018to confer patent eligibility upon the claims at issue.\u2019\u201d\n\n Affinity Labs, 838 F.3d at 1263 (quoting Alice); see also Stanford II, 991 F.3d at 1252 (holding\n\n that novelty is not the \u201ctouchstone of patent eligibility. That a specific or different combination of\n\n mathematical steps yields more accurate haplotype predictions than previously achievable under\n\n the prior art is not enough to transform the abstract idea in claim 1 into a patent eligible\n\n application\u201d); PersonalWeb, 8 F.4th at 1319.\n\n        The outcome is the same for the independent claims (10 and 18). Inclusion of generic\n\n computer components does not change the Step Two analysis. See Stanford II, 991 F.3d at 1252\n\n (\u201cNor does claim 1 require or result in a specialized computer or a computer with a specialized\n\n memory or processor. Indeed, it is hard to imagine a patent claim that recites hardware\n\n limitations in more generic terms than the terms employed by claim 1\u201d where the claimed\n\n method steps were carried out by a \u201ccomputer system\u201d with a \u201cprocessor\u201d and a \u201cmemory\u201d).\n\n        Additional limitations in the dependent claims also do not add any inventive concepts.\n\n They either add further features related to the abstract idea (the variation of the Montgomery\n\n reduction) itself, such as providing the equation of n\u2019 (claims 2, 11, 19), further replacing words\n\n\n\n\n                                                   29\n\fCase 2:25-cv-00519-JRG-RSP            Document 114 Filed 06/24/26              Page 36 of 39 PageID\n                                           #: 3700\n\n\n\n of the operand using a reduction value (claims 3, 12, 20), discussing the steps of a standard\n\n Montgomery reduction (claims 4, 13, 21), identifying that the reduction value is pre-computed\n\n (claims 6, 14, 22), shifting words of the operand (claims 7, 15, 23), adding a carry to the output if\n\n a carry is produced (claims 8, 16, 24), and listing multiplication or squaring as cryptographic\n\n operation (claims 9, 17, 25), or reciting a generic computer component such as the use of a\n\n Montgomery engine (claim 5). TLI, 823 F.3d at 614 (\u201cour precedent[s] find[] generic computer\n\n components insufficient to add an inventive concept to an otherwise abstract idea\u201d);\n\n PersonalWeb, 8 F.4th at 1319 (\u201c[O]ur precedent is clear that merely adding computer\n\n functionality to increase the speed or efficiency of the process does not confer patent eligibility\n\n on an otherwise abstract idea.\u201d).\n\n        Because all claims of the 286 Patent fail the two-step test under Alice, the claims should\n\n be held invalid under 35 U.S.C. \u00a7 101.\n\n VIII. CONCLUSION\n\n        Core Scientific respectfully requests that the Court grant its motion to dismiss from the\n\n Plaintiffs\u2019 Second Amended Complaint the 827 Patent, the 370 Patent, the 062 Patent, the 960\n\n Patent, and the 286 Patent, as these patents\u2019 claims are directed to abstract concepts ineligible for\n\n patent protection under 35 U.S.C. \u00a7 101. These claims describe mathematical algorithms that\n\n humans could perform using pencil and paper, and at most add generic computer components\n\n functioning in a conventional way. Resolving these eligibility issues does not require discovery\n\n or claim construction and is ripe for consideration now.\n\n\n\n\n                                                  30\n\fCase 2:25-cv-00519-JRG-RSP   Document 114 Filed 06/24/26        Page 37 of 39 PageID\n                                  #: 3701\n\n\n\n Dated: June 24, 2026                     Respectfully submitted,\n\n                                           /s/ Brian E. Ferguson\n                                           Brian E. Ferguson\n                                           KING & SPALDING LLP\n                                           1700 Pennsylvania Avenue, NW\n                                           Suite 900\n                                           Washington, D.C. 20006\n                                           Telephone: (202) 737-0500\n                                           Email: bferguson@kslaw.com\n\n                                           Rex A. Mann\n                                           Texas Bar No. 24075509\n                                           KING & SPALDING LLP\n                                           2601 Olive Street\n                                           Suite 2300\n                                           Dallas, TX 75201\n                                           Tel.: (214) 764-4600\n                                           Email: rmann@kslaw.com\n\n                                           John Tyler Boyce\n                                           Texas Bar No. 24127214\n                                           KING & SPALDING LLP\n                                           1100 Louisiana, Suite 4100\n                                           Houston, TX 77002\n                                           Tel.: (713) 276-7324\n                                           Email: tboyce@kslaw.com\n\n                                          Attorneys for Core Scientific, Inc.\n\n\n\n\n                                     31\n\fCase 2:25-cv-00519-JRG-RSP             Document 114 Filed 06/24/26          Page 38 of 39 PageID\n                                            #: 3702\n\n\n\n\n                  CERTIFICATE OF COMPLIANCE WITH THE COURT\u2019S\n                      35 U.S.C. \u00a7 101 MOTION PRACTICE ORDER\n\n\n         _____ The parties agree that prior claim construction is not needed to inform the Court\u2019s\n\n analysis as to patentability.\n\n\n           X xThe parties disagree on whether prior claim construction is not needed to inform\n\n the Court\u2019s analysis as to patentability.\n\n\n\n\n                                               /s/ Brian E. Ferguson\n                                              Brian E. Ferguson\n\n\n\n\n                                                 32\n\fCase 2:25-cv-00519-JRG-RSP          Document 114 Filed 06/24/26            Page 39 of 39 PageID\n                                         #: 3703\n\n\n\n                                CERTIFICATE OF SERVICE\n\n        I certify that a true and correct copy of the foregoing document has been served on\n\n counsel of record, who are deemed to have consented to electronic service, on June 24, 2026, via\n\n electronic filing using the Court\u2019s CM/ECF system.\n\n\n                                              /s/ Brian E. Ferguson\n                                             Brian E. Ferguson\n\n\n\n\n                                                33\n\f","ocr_status":2,"date_upload":"2026-06-25T07:01:45.827558-07:00","document_number":"114","attachment_number":null,"pacer_doc_id":"175015487223","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Dismiss","acms_document_guid":""},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/484004413/","id":484004413,"tags":[],"absolute_url":"/docket/70244989/114/1/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-06-25T07:01:34.034494-07:00","date_modified":"2026-06-25T07:01:34.034507-07:00","sha1":"","page_count":1,"file_size":88974,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"114","attachment_number":1,"pacer_doc_id":"175015487224","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":2,"description":"Proposed Order Granting Defendant's Motion to Dismiss","acms_document_guid":""}],"date_created":"2026-06-24T16:12:53.748839-07:00","date_modified":"2026-08-26T18:56:49.920459-07:00","date_filed":"2026-06-24","time_filed":"17:57:06","entry_number":114,"recap_sequence_number":"2026-06-24.001","pacer_sequence_number":318,"description":"MOTION to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6) and 35 U.S.C. 101 by Core Scientific, Inc.. (Attachments: # 1 Proposed Order Granting Defendant's Motion to Dismiss)(Ferguson, Brian) (Entered: 06/24/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/468307999/","id":468307999,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/70244989/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/483597525/","id":483597525,"tags":[],"absolute_url":"/docket/70244989/113/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-06-22T12:52:54.541534-07:00","date_modified":"2026-06-25T05:50:30.295523-07:00","sha1":"b2926f64fd5a4de0c9e7cffe19eb1ac9bdd6ab4d","page_count":1,"file_size":920448,"filepath_local":"recap/gov.uscourts.txed.237820/gov.uscourts.txed.237820.113.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.txed.237820/gov.uscourts.txed.237820.113.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 2:25-cv-00519-JRG-RSP           Document 113       Filed 06/22/26     Page 1 of 1 PageID #:\n                                            3664\n\n\n\n                         IN THE UNITED STATES DISTRICT COURT\n                          FOR THE EASTERN DISTRICT OF TEXAS\n                                  MARSHALL DIVISION\n\n     MALIKIE INNOVATIONS LTD. and                \u00a7\n     KEY PATENT INNOVATIONS LTD.,                \u00a7\n .                                               \u00a7\n                  Plaintiffs,\n                                                 \u00a7\n     v.                                          \u00a7      CASE NO. 2:25-CV-00519-JRG-RSP\n     CORE SCIENTIFIC, INC.,                      \u00a7\n                                                 \u00a7\n                  Defendant.                     \u00a7\n\n                                             ORDER\n\n          Before the Court is Defendant\u2019s Unopposed Motion to Extend Deadline for Core Scientific\n\n to Respond to the Second Amended Complaint. Dkt. No. 109. Having considered the Motion, the\n\n Court finds that it should be and hereby is GRANTED. Accordingly, it is\n\n          ORDERED  that3rd\n          SIGNED this    theday\n                             deadline for Defendant\n                                of January,  2012. to respond is extended to June 24, 2026.\n          SIGNED this 19th day of June, 2026.\n\n\n\n\n                                                     ____________________________________\n                                                     ROY S. PAYNE\n                                                     UNITED STATES MAGISTRATE JUDGE\n\f","ocr_status":2,"date_upload":"2026-06-24T14:22:53.320224-07:00","document_number":"113","attachment_number":null,"pacer_doc_id":"175015476964","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order on Motion for Extension of Time to Answer","acms_document_guid":""}],"date_created":"2026-06-22T12:52:54.512388-07:00","date_modified":"2026-06-24T14:21:01.906517-07:00","date_filed":"2026-06-22","time_filed":"14:14:02","entry_number":113,"recap_sequence_number":"2026-06-22.001","pacer_sequence_number":316,"description":"ORDER granting 109 Motion to Extend Deadline for Core Scientific to Respond to the Second Amended Complaint. Signed by Magistrate Judge Roy S. Payne on 06/19/2026. (mdj) (Entered: 06/22/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/467542083/","id":467542083,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/70244989/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/482808451/","id":482808451,"tags":[],"absolute_url":"/docket/70244989/111/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-06-15T17:55:33.278990-07:00","date_modified":"2026-06-18T03:35:58.805918-07:00","sha1":"22098ff590e66be8b117eb4ccd262b656cac3bcd","page_count":16,"file_size":252632,"filepath_local":"recap/gov.uscourts.txed.237820/gov.uscourts.txed.237820.111.0.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.txed.237820/gov.uscourts.txed.237820.111.0.pdf","ia_upload_failure_count":null,"thumbnail":"recap-thumbnails/gov.uscourts.txed.237820/482808451.thumb.1068.png","thumbnail_status":1,"plain_text":"Case 2:25-cv-00519-JRG-RSP           Document 111        Filed 06/15/26        Page 1 of 16 PageID #:\n                                            3645\n\n\n\n                        IN THE UNITED STATES DISTRICT COURT\n                         FOR THE EASTERN DISTRICT OF TEXAS\n                                 MARSHALL DIVISION\n\n  MALIKIE INNOVATIONS LTD. and\n  KEY PATENT INNOVATIONS LTD.,\n\n                 Plaintiffs,                           Civil Action No: 2:25-cv-519-JRG-RSP\n         v.                                                        PATENT CASE\n  CORE SCIENTIFIC, INC. and\n                                                              JURY TRIAL DEMAND\n  COREWEAVE, INC.,\n\n                 Defendants.\n\n  CORE SCIENTIFIC, INC.,\n\n                 Defendant and Third-Party\n                 Plaintiff,\n\n         v.\n\n  COREWEAVE, INC.,\n\n                 Third-Party Defendant.\n\n\n\n   DEFENDANT AND THIRD-PARTY DEFENDANT COREWEAVE, INC.\u2019S ANSWER\n       TO CORE SCIENTIFIC, INC.\u2019S THIRD-PARTY COMPLAINT (DKT. 89)\n\n        Defendant and Third-Party Defendant CoreWeave, Inc. (\u201cCoreWeave\u201d), by and through\n\n its attorneys, answers the Third-Party Complaint (\u201cThird-Party Complaint\u201d) of Defendant and\n\n Third-Party Plaintiff Core Scientific, Inc. (\u201cCore Scientific\u201d) as follows:\n\n        CoreWeave denies all allegations and claims in the Third-Party Complaint unless\n\n expressly admitted in the following paragraphs. Any factual allegations admitted below are\n\n admitted only as to the specific admitted facts, and not as to any purported conclusions,\n\n characterizations, implications, or speculations that might follow. To the extent a response is\n\n required and not explicitly given here, CoreWeave denies such allegations.\n\n\n\n                                                  1\n\fCase 2:25-cv-00519-JRG-RSP            Document 111         Filed 06/15/26      Page 2 of 16 PageID #:\n                                             3646\n\n\n\n        CoreWeave\u2019s responses are made solely with respect to the Third-Party Complaint and\n\n are not, and shall not be construed as, admissions of any kind in connection with the claims\n\n asserted by Plaintiffs Malikie Innovations Ltd. and Key Patent Innovations Ltd. (collectively,\n\n \u201cPlaintiffs\u201d), all of which CoreWeave expressly denies.\n\n        The headings used in the Third-Party Complaint are reproduced below for organizational\n\n convenience only; CoreWeave does not admit any allegation, characterization, or implication\n\n contained in any heading and denies each to the extent a response is deemed required.\n\n        CoreWeave responds to the numbered paragraphs of the Third-Party Complaint as\n\n follows:\n\n                                       NATURE OF ACTION\n\n        1.      Paragraph 1 of the Third-Party Complaint purports to describe allegations made\n\n by Plaintiffs against Core Scientific concerning U.S. Patent Nos. 8,532,286 (the \u201c\u2019286 Patent\u201d)\n\n and 8,712,039 (the \u201c\u2019039 Patent\u201d) (collectively, the \u201cAsserted Patents\u201d). CoreWeave lacks\n\n knowledge or information sufficient to form a belief as to the truth of Plaintiffs\u2019 allegations\n\n against Core Scientific, and on that basis, denies any allegations in Paragraph 1 of the Third-\n\n Party Complaint.\n\n        2.      Paragraph 2 of the Third-Party Complaint purports to incorporate by reference\n\n allegations from Plaintiffs\u2019 First Amended Complaint solely for purposes of describing\n\n Plaintiffs\u2019 allegations against Core Scientific. CoreWeave lacks knowledge or information\n\n sufficient to form a belief as to the truth of Plaintiffs\u2019 allegations against Core Scientific, and on\n\n that basis, denies them. CoreWeave denies that Core Scientific is entitled to indemnification\n\n from CoreWeave under any agreement between Core Scientific and CoreWeave. CoreWeave\n\n\n\n\n                                                    2\n\fCase 2:25-cv-00519-JRG-RSP           Document 111        Filed 06/15/26      Page 3 of 16 PageID #:\n                                            3647\n\n\n\n denies the remaining allegations and characterizations in Paragraph 2 of the Third-Party\n\n Complaint.\n\n                                             PARTIES\n\n        3.      In Paragraph 3 of the Third-Party Complaint, Core Scientific purports to identify\n\n itself as a Delaware corporation and provides data center and colocation services to customers.\n\n CoreWeave lacks knowledge or information sufficient to form a belief as to the truth of the\n\n allegations concerning Core Scientific\u2019s corporate address, headquarters, main corporate campus,\n\n and the full scope of Core Scientific\u2019s business operations, and on that basis, denies those\n\n allegations. CoreWeave denies any remaining allegations in Paragraph 3 of the Third-Party\n\n Complaint.\n\n        4.      CoreWeave admits that it is a Delaware Corporation with a principal place of\n\n business at 290 W Mount Pleasant Ave, Suite 4100, Livingston, NJ 07039. CoreWeave admits\n\n that it provides certain cloud computing services and that its computing infrastructure includes\n\n certain NVIDIA graphics processing units and data processing units. CoreWeave denies any\n\n remaining allegations and characterizations in Paragraph 4 of the Third-Party Complaint.\n\n        5.      CoreWeave admits that it and Core Scientific entered into an Amended and\n\n Restated Colocation License Agreement (the \u201cAgreement\u201d) dated February 26, 2025.\n\n CoreWeave states that the Agreement speaks for itself, and denies any allegation in Paragraph 5\n\n inconsistent with the Agreement\u2019s terms. CoreWeave denies that it has committed or is\n\n committing any acts of infringement in this District or anywhere else. CoreWeave denies that\n\n Core Scientific is entitled to any of the relief requested in the Third-Party Complaint.\n\n CoreWeave denies any remaining allegations and characterizations in Paragraph 5 of the Third-\n\n Party Complaint.\n\n\n\n\n                                                  3\n\fCase 2:25-cv-00519-JRG-RSP           Document 111         Filed 06/15/26      Page 4 of 16 PageID #:\n                                            3648\n\n\n\n                                  JURISDICTION AND VENUE\n\n        6.      Paragraph 6 of the Third-Party Complaint states legal conclusions and\n\n characterizations to which no response is required. To the extent a response is required,\n\n CoreWeave admits that Plaintiffs\u2019 First Amended Complaint purports to assert claims for patent\n\n infringement against Core Scientific arising under the patent laws of the United States.\n\n CoreWeave lacks knowledge or information sufficient to form a belief as to the truth of\n\n Plaintiffs\u2019 allegations against Core Scientific, and on that basis denies them and denies any\n\n remaining allegations in Paragraph 6.\n\n        7.      Paragraph 7 states legal conclusions and characterizations to which no response is\n\n required. To the extent a response is required, CoreWeave admits that Core Scientific purports to\n\n invoke this Court\u2019s subject matter jurisdiction under 28 U.S.C. \u00a7\u00a7 1331, 1338(a), 1367(a), and\n\n 1332. CoreWeave denies that Core Scientific\u2019s liability, if any, is based solely on CoreWeave\u2019s\n\n equipment or activities, and denies any remaining allegations in Paragraph 7.\n\n        8.      Paragraph 8 states legal conclusions and characterizations concerning personal\n\n jurisdiction to which no response is required. To the extent a response is required, CoreWeave\n\n does not contest, for purposes of this action only, that this Court has personal jurisdiction over\n\n CoreWeave. CoreWeave denies that it has committed or is committing any act of infringement in\n\n this District or anywhere else. CoreWeave denies that Core Scientific\u2019s liability, if any, is based\n\n solely on CoreWeave\u2019s equipment or activities. CoreWeave denies that Core Scientific is entitled\n\n to any of the relief requested in the Third-Party Complaint. CoreWeave denies any remaining\n\n allegations in Paragraph 8.\n\n        9.      Paragraph 9 states legal conclusions concerning venue to which no response is\n\n required. To the extent a response is required, CoreWeave does not contest, for purposes of this\n\n action only, that venue is proper in this District in this case but denies that venue is convenient\n\n\n                                                   4\n\fCase 2:25-cv-00519-JRG-RSP           Document 111        Filed 06/15/26      Page 5 of 16 PageID #:\n                                            3649\n\n\n\n in this case. CoreWeave denies that it has committed or is committing acts of infringement in\n\n this District or anywhere else. CoreWeave denies that Core Scientific\u2019s liability, if any, is based\n\n solely on CoreWeave\u2019s equipment or activities. CoreWeave denies that Core Scientific is entitled\n\n to any of the relief requested in the Third-Party Complaint. CoreWeave denies any remaining\n\n allegations in Paragraph 9.\n\n                                    FACTUAL ALLEGATIONS\n\n        A.      The [Alleged] Underlying Patent Infringement Action\n\n        10.     CoreWeave admits that Plaintiffs filed a Complaint for Patent Infringement\n\n against Core Scientific on or about May 12, 2025, and a First Amended Complaint on or about\n\n November 13, 2025. CoreWeave states that Plaintiffs\u2019 pleadings speak for themselves.\n\n CoreWeave lacks knowledge or information sufficient to form a belief as to the truth of\n\n Plaintiffs\u2019 allegations against Core Scientific, and on that basis, denies the remaining allegations\n\n in Paragraph 10. CoreWeave denies that CoreWeave infringes any valid and enforceable claim of\n\n any Asserted Patent, and denies any characterization of infringement.\n\n        11.     Paragraph 11 purports to characterize allegations and infringement contentions\n\n made by Plaintiffs. CoreWeave states that Plaintiffs' pleadings and infringement contentions\n\n speak for themselves. CoreWeave lacks knowledge or information sufficient to form a belief as\n\n to the truth of Plaintiffs\u2019 allegations and infringement contentions against Core Scientific\n\n concerning the \u2019286 Patent, and on that basis denies them. CoreWeave denies that any equipment\n\n or activity of CoreWeave infringes any valid and enforceable claim of the \u2019286 Patent.\n\n        12.     Paragraph 12 purports to characterize allegations and infringement contentions\n\n made by Plaintiffs. CoreWeave states that Plaintiffs' pleadings and infringement contentions\n\n speak for themselves. CoreWeave lacks knowledge or information sufficient to form a belief as\n\n to the truth of Plaintiffs\u2019 allegations and infringement contentions against Core Scientific\n\n\n                                                  5\n\fCase 2:25-cv-00519-JRG-RSP          Document 111        Filed 06/15/26      Page 6 of 16 PageID #:\n                                           3650\n\n\n\n concerning the \u2019039 Patent, and on that basis denies them. CoreWeave denies that any equipment\n\n or activity of CoreWeave infringes any valid and enforceable claim of the \u2019039 Patent.\n\n        B.      [Alleged] Core Scientific\u2019s HPC Hosting Relationship with CoreWeave\n\n        13.     CoreWeave admits that Core Scientific provides certain data center colocation\n\n services to CoreWeave at certain Core Scientific\u2019s facilities pursuant to one or more written\n\n agreements. To the extent Paragraph 13 purports to characterize the terms of any agreement\n\n between CoreWeave and Core Scientific, or paraphrase any public document or statement made\n\n either by CoreWeave or Core Scientific, CoreWeave states that the relevant documents speak for\n\n themselves. CoreWeave denies the remaining allegations of Paragraph 13 of the Third-Party\n\n Complaint.\n\n        14.     To the extent Paragraph 14 purports to describe the terms of any agreement or\n\n option between CoreWeave and Core Scientific, or paraphrase any public document or statement\n\n made either by CoreWeave or Core Scientific, CoreWeave states that the relevant documents\n\n speak for themselves. CoreWeave denies the remaining allegations of Paragraph 14 of the\n\n Third-Party Complaint.\n\n        15.     CoreWeave admits that, in February 2025, Core Scientific and CoreWeave\n\n announced a $1.2 billion expansion at Core Scientific\u2019s Denton, Texas site. To the extent\n\n Paragraph 15 purports to characterize the terms of any agreement between CoreWeave and Core\n\n Scientific, or paraphrase any public statement made either by CoreWeave or Core Scientific,\n\n CoreWeave states that the relevant documents speak for themselves. CoreWeave lacks\n\n knowledge or information sufficient to form a belief as to the truth of the remaining allegations\n\n in Paragraph 15, and on that basis denies those allegations.\n\n\n\n\n                                                  6\n\fCase 2:25-cv-00519-JRG-RSP            Document 111         Filed 06/15/26       Page 7 of 16 PageID #:\n                                             3651\n\n\n\n         16.     To the extent Paragraph 16 purports to describe the terms of any agreement\n\n between CoreWeave and Core Scientific, or paraphrase any public document or statement made\n\n either by CoreWeave or Core Scientific, CoreWeave states that the relevant documents speak for\n\n themselves. CoreWeave denies that any equipment identified in Paragraph 16 infringes any valid\n\n and enforceable claim of the Asserted Patents. CoreWeave lacks knowledge or information\n\n sufficient to form a belief as to the truth of the remaining allegations in Paragraph 16, and on that\n\n basis denies those allegations.\n\n         17.     To the extent Paragraph 17 of the Third-Party Complaint purports to characterize\n\n or paraphrase Plaintiffs\u2019 infringement contentions and any public material, CoreWeave states\n\n that the relevant documents speak for themselves. CoreWeave lacks knowledge or information\n\n sufficient to form a belief as to the truth of Core Scientific\u2019s characterization of Plaintiffs\u2019\n\n infringement contentions, and on that basis, denies all such allegations. CoreWeave denies any\n\n remaining allegations in Paragraph 17.\n\n         C.      [Alleged] CoreWeave\u2019s Ownership and Operation of the Accused Devices\n\n         18.     CoreWeave denies that it owns the accused NVIDIA GPUs and DPUs hosted at\n\n certain Core Scientific\u2019s data centers, and states that ownership of such equipment is subject to\n\n other contractual arrangements. To the extent this paragraph purports to paraphrase or\n\n characterize the contents of a written document, the document speaks for itself, and therefore no\n\n response is necessary. CoreWeave denies the remaining allegations in Paragraph 18 of the\n\n Third-Party Complaint.\n\n         19.     CoreWeave admits that it operates certain equipment used in connection with its\n\n business but denies that such operation infringes any valid and enforceable claim of the Asserted\n\n Patents. To the extent this paragraph purports to paraphrase or characterize the contents of a\n\n\n\n\n                                                    7\n\fCase 2:25-cv-00519-JRG-RSP           Document 111        Filed 06/15/26      Page 8 of 16 PageID #:\n                                            3652\n\n\n\n written document, the document speaks for itself, and therefore no response is necessary.\n\n CoreWeave denies the remaining allegations in Paragraph 19 of the Third-Party Complaint.\n\n        D.      Core Weave [Allegedly] Agreed to Indemnify Core Scientific\n\n        20.     Paragraph 20 states legal conclusions and characterizations of the parties\u2019\n\n agreement(s) to which no response is required. To the extent a response is required, CoreWeave\n\n states that any agreement between the parties is a written instrument that speaks for itself.\n\n CoreWeave denies that it is obligated to defend, indemnify, hold harmless Core Scientific with\n\n respect to the claims asserted by Plaintiffs in this action. CoreWeave denies the remaining\n\n allegations of Paragraph 20.\n\n        E.      CoreWeave\u2019s [Alleged] Liability for Direct Infringement\n\n        21.     Paragraph 21 of the Third-Party Complaint states legal conclusions and\n\n characterizations to which no response is required. To the extent a response is required,\n\n CoreWeave denies that Plaintiffs\u2019 allegations of infringement are meritorious and denies that\n\n CoreWeave directly infringes any valid and enforceable claim of the Asserted Patents.\n\n CoreWeave denies the remaining allegations of Paragraph 21.\n\n        22.     Paragraph 22 of the Third-Party Complaint states legal conclusions and\n\n characterizations to which no response is required. To the extent a response is required,\n\n CoreWeave admits that it owns and operates its own computing equipment, but denies that any\n\n such equipment infringes any valid and enforceable claim of the Asserted Patents. To the extent\n\n Paragraph 22 purports to describe any agreement between the parties, the agreement(s) speak for\n\n themselves. As to the allegations characterizing Core Scientific\u2019s own role and conduct,\n\n CoreWeave lacks knowledge or information sufficient to form a belief and on that basis denies\n\n them. CoreWeave denies that any infringement of the Asserted Patents has occurred, and denies\n\n\n\n\n                                                  8\n\fCase 2:25-cv-00519-JRG-RSP            Document 111        Filed 06/15/26       Page 9 of 16 PageID #:\n                                             3653\n\n\n\n that any liability of Core Scientific would be \u201cderivative of and secondary to\u201d any direct\n\n infringement by CoreWeave. CoreWeave denies the remaining allegations of Paragraph 22.\n\n                                 COUNT I: INDEMNIFICATION\n\n         23.     CoreWeave repeats and incorporates by reference its responses to Paragraphs 1\n\n through 22 as if fully set forth herein.\n\n         24.     CoreWeave admits that Plaintiffs filed a Complaint against Core Scientific\n\n alleging patent infringement on or about May 12, 2025, and a First Amended Complaint on or\n\n about November 13, 2025, and that Core Scientific purports to incorporate Plaintiffs\u2019 First\n\n Amended Complaint by reference. CoreWeave denies any remaining allegations in Paragraph\n\n 24.\n\n         25.     Paragraph 25 of the Third-Party Complaint states legal conclusions and\n\n characterizations to which no response is required. To the extent a response is required,\n\n CoreWeave denies that any conduct of CoreWeave constitutes active or affirmative conduct\n\n giving rise to liability or to any duty to indemnify. CoreWeave denies any remaining allegations\n\n in Paragraph 25.\n\n         26.     Paragraph 26 of the Third-Party Complaint states legal conclusions and\n\n characterizations to which no response is required. To the extent a response is required,\n\n CoreWeave admits that Core Scientific denies liability to Plaintiffs. CoreWeave denies that it is\n\n obligated to indemnify, defend, hold harmless, reimburse, or otherwise compensate Core\n\n Scientific for the claims asserted by Plaintiffs or for the relief sought in the Third-Party\n\n Complaint. CoreWeave denies any remaining allegations in Paragraph 26.\n\n         27.     Paragraph 27 of the Third-Party Complaint states legal conclusions and\n\n characterizations to which no response is required. To the extent a response is required,\n\n\n\n\n                                                   9\n\fCase 2:25-cv-00519-JRG-RSP             Document 111 Filed 06/15/26              Page 10 of 16 PageID\n                                            #: 3654\n\n\n\n CoreWeave denies that any liability or responsibility of Core Scientific would be the direct or\n\n proximate result of CoreWeave\u2019s conduct. CoreWeave denies any remaining allegations in\n\n Paragraph 27.\n\n         28.      Paragraph 28 of the Third-Party Complaint states legal conclusions and requests\n\n for relief to which no response is required. To the extent a response is required, CoreWeave\n\n denies that Core Scientific is entitled to indemnification, costs, attorneys\u2019 fees, or any other relief\n\n from CoreWeave.\n\n                                   COUNT II: CONTRIBUTION\n\n         29.      CoreWeave repeats and incorporates by reference its responses to Paragraphs 1\n\n through 22 as if fully set forth herein.\n\n         30.      Paragraph 30 of the Third-Party Complaint states legal conclusions and\n\n characterizations to which no response is required. To the extent a response is required,\n\n CoreWeave denies liability and denies that Core Scientific is entitled to contribution from\n\n CoreWeave. CoreWeave denies any remaining allegations in Paragraph 30.\n\n         31.      CoreWeave denies the allegations of Paragraph 31 of the Third-Party Complaint,\n\n including that Core Scientific is entitled to a declaratory judgment.\n\n                                            JURY DEMAND\n\n         32.      CoreWeave is not required to provide a response to Core Scientific\u2019s request for\n\n trial by jury.\n\n                             RESPONSE TO PRAYER FOR RELIEF\n\n         CoreWeave denies that Core Scientific is entitled to any of the relief requested in the\n\n unnumbered \u201cPrayer for Relief\u201d paragraphs (including subparagraphs A through D) following\n\n Paragraph 32 of the Third-Party Complaint, or to any relief whatsoever, whether against\n\n\n\n\n                                                   10\n\fCase 2:25-cv-00519-JRG-RSP             Document 111 Filed 06/15/26               Page 11 of 16 PageID\n                                            #: 3655\n\n\n\n CoreWeave or otherwise. CoreWeave specifically denies that Core Scientific is entitled to\n\n indemnification or contribution from CoreWeave; to any money damages, enhanced damages,\n\n royalties, interest, costs, or fees; to any costs, expenses, professional fees, or attorneys\u2019 fees, or to\n\n any other or further relief. To the extent any allegation in the Third-Party Complaint is not\n\n specifically admitted herein, it is denied.\n\n                                               DEFENSES\n\n         Without admitting any allegation of the Third-Party Complaint, and without assuming any\n\n burden of proof that it would not otherwise bear, CoreWeave asserts the following defenses.\n\n CoreWeave reserves the right to amend this Answer to add additional Affirmative Defenses\n\n consistent with the facts discovered in this case.\n\n                                               First Defense\n\n         CoreWeave has not infringed and does not infringe, either directly or indirectly, literally\n\n or under the doctrine of equivalents, and under no theory of infringement, any valid and\n\n enforceable claim of U.S. Patent Nos. 8,532,286 and 8,712,039 (the \u201cAsserted Patents\u201d). In the\n\n absence of any underlying infringement by CoreWeave, Core Scientific\u2019s claims for\n\n indemnification and contribution fail as a matter of law.\n\n                                            Second Defense\n\n         Each asserted claim of the Asserted Patents is invalid for failure to comply with one or\n\n more of the requirements of Title 35 of the United States Code, including without limitation, 35\n\n U.S.C. \u00a7\u00a7 101, 102, 103, and 112, and the rules, regulations, and laws pertaining thereto.\n\n                                               Third Defense\n\n         Core Scientific\u2019s indemnification claims are barred, in whole or in part, because\n\n CoreWeave has no obligation to defend, indemnify, hold harmless, reimburse, or otherwise\n\n\n                                                    11\n\fCase 2:25-cv-00519-JRG-RSP            Document 111 Filed 06/15/26              Page 12 of 16 PageID\n                                           #: 3656\n\n\n\n compensate Core Scientific for the claims, damages, fees, costs, or other relief sought in the\n\n Third-Party Complaint.\n\n                                           Fourth Defense\n\n        Core Scientific\u2019s contribution claims are barred, in whole or in part, because Core\n\n Scientific has not established, and cannot establish, any legal basis for contribution from\n\n CoreWeave for the patent infringement claims asserted by Plaintiffs against Core Scientific.\n\n                                            Fifth Defense\n\n        Core Scientific\u2019s contribution claims are barred, in whole or in part, because there is no\n\n federal common-law right of contribution among alleged joint tortfeasors absent statutory\n\n creation\n\n                                            Sixth Defense\n\n        The Third-Party Complaint fails to state a claim upon which relief can be granted, in\n\n whole or in part.\n\n                                           Seventh Defense\n\n        Core Scientific\u2019s claims for indemnification and contribution are barred or reduced, in\n\n whole or in part, to the extent that any liability of Core Scientific arises from Core Scientific's\n\n own independent acts, omissions, products, services, or conduct\u2014including, without limitation,\n\n Core Scientific\u2019s own activities separately accused by Plaintiffs\u2014which are independent of, and\n\n not attributable to, CoreWeave and which fall outside the scope of any indemnity or contribution\n\n obligation owed by CoreWeave.\n\n                                           Eighth Defense\n\n        Core Scientific\u2019s indemnification claim is barred, in whole or in part, because the\n\n indemnification, defense, and hold-harmless provisions of the parties\u2019 agreement(s) do not\n\n\n\n\n                                                   12\n\fCase 2:25-cv-00519-JRG-RSP             Document 111 Filed 06/15/26             Page 13 of 16 PageID\n                                            #: 3657\n\n\n\n encompass, and were not intended to encompass, third-party claims of patent infringement of the\n\n nature asserted by Plaintiffs in this action.\n\n                                             Ninth Defense\n\n         Core Scientific\u2019s indemnification claim is barred, in whole or in part, by its failure to\n\n satisfy one or more conditions precedent to any indemnity obligation under the parties\u2019\n\n agreement(s), including without limitation any requirements concerning timely notice, tender of\n\n defense, cooperation, control of the defense and settlement, and other procedural and substantive\n\n prerequisites set forth in the operative agreement(s).\n\n                                             Tenth Defense\n\n         Core Scientific\u2019s claims are barred or limited, in whole or in part, by the express terms of\n\n the parties' agreement(s), including without limitation any provisions limiting or excluding\n\n liability, waiving consequential, incidental, indirect, special, or punitive damages, capping\n\n aggregate liability, allocating risk, and/or carving out intellectual-property or other claims from\n\n indemnification.\n\n                                           Eleventh Defense\n\n         Core Scientific\u2019s claims are barred or reduced, in whole or in part, by its failure to take\n\n reasonable steps to mitigate, minimize, or avoid its alleged damages.\n\n                                           Twelfth Defense\n\n         To the extent Core Scientific is entitled to any recovery, which CoreWeave denies, any\n\n such recovery must be reduced or offset by amounts owed by Core Scientific to CoreWeave and\n\n by Core Scientific\u2019s own breaches, fault, and independent conduct.\n\n\n\n\n                                                  13\n\fCase 2:25-cv-00519-JRG-RSP           Document 111 Filed 06/15/26             Page 14 of 16 PageID\n                                          #: 3658\n\n\n\n                                        Thirteenth Defense\n\n        Core Scientific's claims are barred or reduced, in whole or in part, by Core Scientific's\n\n own prior material breach of the parties\u2019 agreement(s) and/or by the doctrine of unclean hands, to\n\n the extent Core Scientific has failed to perform its own obligations under the operative\n\n agreement(s).\n\n                                        Fourteenth Defense\n\n        To the extent Core Scientific\u2019s claims depend upon Plaintiffs\u2019 recovery against Core\n\n Scientific, any such recovery, and therefore any derivative indemnification or contribution, is\n\n barred or limited by the limitations on damages and recovery set forth in 35 U.S.C. \u00a7\u00a7 286 and\n\n 287, and by any other applicable limitation on the recovery of damages.\n\n                                         Fifteenth Defense\n\n        To the extent Core Scientific seeks to recover enhanced damages or attorneys\u2019 fees\n\n derived from any finding of willfulness or exceptional-case status, such recovery is barred\n\n because there has been no willful infringement and this is not an exceptional case under 35\n\n U.S.C. \u00a7\u00a7 284 or 285.\n\n                                      Reservation of Rights\n\n        CoreWeave reserves the right to assert additional defenses, affirmative defenses,\n\n counterclaims, cross-claims, and third-party claims as they become known through discovery or\n\n otherwise, and reserves the right to amend this Answer accordingly. CoreWeave does not\n\n knowingly or intentionally waive any applicable defense.\n\n                                     PRAYER FOR RELIEF\n\n        WHEREFORE, CoreWeave respectfully requests that the Court enter judgment in its\n\n favor and against Core Scientific as follows:\n\n\n\n\n                                                 14\n\fCase 2:25-cv-00519-JRG-RSP                 Document 111 Filed 06/15/26         Page 15 of 16 PageID\n                                                #: 3659\n\n\n\n            A. That Core Scientific take nothing by its Third-Party Complaint;\n\n            B. That the Third-Party Complaint be dismissed in its entirety, with prejudice;\n\n            C. That judgment be entered in favor of CoreWeave on each of Core Scientific\u2019s\n\n claims for indemnification and contribution;\n\n            D. That the Court declare that CoreWeave owes no duty to defend, indemnify, hold\n\n harmless, or contribute to Core Scientific with respect to the claims asserted by Plaintiffs in this\n\n action; and\n\n            E. That CoreWeave be awarded such other and further relief as the Court deems just\n\n and proper.\n\n                                    DEMAND FOR JURY TRIAL\n\n         Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, CoreWeave demands a\n\n trial by jury on all issues so triable.\n\n\n\n\n                                                   15\n\fCase 2:25-cv-00519-JRG-RSP          Document 111 Filed 06/15/26               Page 16 of 16 PageID\n                                         #: 3660\n\n\n\n Dated: June 15, 2026                               Respectfully submitted,\n\n                                             By: /s/ Adam J. Kessel\n                                                 Ricardo J. Bonilla\n                                                 Texas Bar No. 24082704\n                                                 rbonilla@fr.com\n                                                 FISH & RICHARDSON P.C.\n                                                 1717 Main Street, Suite 5000\n                                                 Dallas, Texas 75201\n                                                 (214) 747-5070 (Telephone)\n                                                 (214) 747-2091 (Facsimile)\n\n                                                    Eli Svetlov\n                                                    Texas Bar No. 24106483\n                                                    svetlov@fr.com\n                                                    Nicholas J. Valencia\n                                                    Texas Bar No. 24149774\n                                                    valencia@fr.com\n                                                    FISH & RICHARDSON P.C.\n                                                    909 Fannin St., Suite 2100\n                                                    Houston, Texas 77010\n                                                    (713) 654-5300 (Telephone)\n                                                    (713) 652-0109 (Facsimile)\n\n                                                    Adam J. Kessel\n                                                    Massachusetts Bar No. 661211\n                                                    kessel@fr.com\n                                                    FISH & RICHARDSON P.C.\n                                                    One Marina Park Drive\n                                                    Boston, MA 02210\n                                                    Tel: (617) 542-5070\n                                                    Fax: (617) 542-8906\n\n                                             Counsel for Defendant and Third-Party Defendant\n                                             CoreWeave, Inc.\n\n                                CERTIFICATE OF SERVICE\n\n        The undersigned hereby certifies that a true and correct copy of the above and foregoing\n\n document has been served on June 15, 2026 to all counsel of record who are deemed to have\n\n consented to electronic service via the Court\u2019s CM/ECF system.\n\n                                                     /s/ Adam J. 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(Svetlov, Ilya) (Entered: 06/10/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/466915923/","id":466915923,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/70244989/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/482166787/","id":482166787,"tags":[],"absolute_url":"/docket/70244989/109/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-06-10T06:14:29.408647-07:00","date_modified":"2026-06-10T06:14:29.416816-07:00","sha1":"","page_count":null,"file_size":null,"filepath_local":null,"filepath_ia":"","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"","ocr_status":null,"date_upload":null,"document_number":"109","attachment_number":null,"pacer_doc_id":"175015450686","is_available":false,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Extension of Time to File Answer","acms_document_guid":""}],"date_created":"2026-06-10T06:14:29.378064-07:00","date_modified":"2026-08-26T18:56:49.791637-07:00","date_filed":"2026-06-10","time_filed":"07:24:34","entry_number":109,"recap_sequence_number":"2026-06-10.001","pacer_sequence_number":305,"description":"UNOPPOSED MOTION for Extension of Time to File Answer re 105 Amended Complaint,, by Core Scientific, Inc.. (Attachments: # 1 Proposed Order)(Ferguson, Brian) (Entered: 06/10/2026)","tags":[]},{"resource_uri":"https://www.courtlistener.com/api/rest/v4/docket-entries/466643881/","id":466643881,"docket":"https://www.courtlistener.com/api/rest/v4/dockets/70244989/","recap_documents":[{"resource_uri":"https://www.courtlistener.com/api/rest/v4/recap-documents/481888153/","id":481888153,"tags":[],"absolute_url":"/docket/70244989/107/malikie-innovations-ltd-v-core-scientific-inc/","date_created":"2026-06-08T08:56:29.759072-07:00","date_modified":"2026-06-10T04:11:00.773521-07:00","sha1":"3e3a38d62a0565c301f5b584ee3d0fefbcbf5e79","page_count":1,"file_size":921110,"filepath_local":"recap/gov.uscourts.txed.237820/gov.uscourts.txed.237820.107.0_1.pdf","filepath_ia":"https://archive.org/download/gov.uscourts.txed.237820/gov.uscourts.txed.237820.107.0.pdf","ia_upload_failure_count":null,"thumbnail":null,"thumbnail_status":0,"plain_text":"Case 2:25-cv-00519-JRG-RSP           Document 107        Filed 06/08/26   Page 1 of 1 PageID #:\n                                            3636\n\n\n\n                        IN THE UNITED STATES DISTRICT COURT\n                         FOR THE EASTERN DISTRICT OF TEXAS\n                                 MARSHALL DIVISION\n\n  MALIKIE INNOVATIONS LTD. and                   \u00a7\n  KEY PATENT INNOVATIONS LTD.,                   \u00a7\n                                                 \u00a7\n                 Plaintiffs,\n                                                 \u00a7\n . v.                                            \u00a7       CASE NO. 2:25-CV-00519-JRG-RSP\n  CORE SCIENTIFIC, INC.,                         \u00a7\n                                                 \u00a7\n                 Defendant.                      \u00a7\n\n                                             ORDER\n\n        Before the Court is Plaintiffs\u2019 Unopposed Motion for Substitution of Lead Counsel. Dkt.\n\n No. 106. Having considered the Motion, and noting its unopposed nature, the Court finds that it\n\n should be and hereby is GRANTED. Accordingly, it is\n\n        ORDERED that Mr. Philip J. Eklem is replaced with Mr. Courtland Reichman as Lead\n\n Counsel for Plaintiffs in the above-captioned case.\n        SIGNED this 3rd day of January, 2012.\n         SIGNED this 7th day of June, 2026.\n\n\n\n\n                                                       ____________________________________\n                                                       ROY S. PAYNE\n                                                       UNITED STATES MAGISTRATE JUDGE\n\f","ocr_status":2,"date_upload":"2026-06-08T12:25:44.499435-07:00","document_number":"107","attachment_number":null,"pacer_doc_id":"175015444370","is_available":true,"is_free_on_pacer":null,"is_sealed":null,"document_type":1,"description":"Order","acms_document_guid":""}],"date_created":"2026-06-08T08:56:29.730264-07:00","date_modified":"2026-08-26T18:56:49.700917-07:00","date_filed":"2026-06-08","time_filed":"10:30:06","entry_number":107,"recap_sequence_number":"2026-06-08.001","pacer_sequence_number":301,"description":"ORDER Granting 106 Motion for Substitution of Lead Counsel. Signed by Magistrate Judge Roy S. Payne on 06/07/2026. (mdj) (Entered: 06/08/2026)","tags":[]}],"entries_total":"https://www.courtlistener.com/api/rest/v4/docket-entries/?count=on&docket=70244989&page_size=40"}