Malikie Innovations Ltd. v. Core Scientific, Inc. — Entry #122: REPLY to Response re 114 MOTION to Dismiss Pursuant to Fed

Case 2:25-cv-00519-JRG-RSP         Document 122    Filed 07/15/26   Page 1 of 16 PageID #:
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                          IN THE UNITED STATES DISTRICT COURT
                           FOR THE EASTERN DISTRICT OF TEXAS
                                   MARSHALL DIVISION

 Malikie Innovations Ltd. and                  §
 Key Patent Innovations Ltd.,                  §
                                               §
                   Plaintiffs,                 §
                                               §      Case No. 2:25-CV-519-JRG-RSP
        v.                                     §
                                               §      JURY TRIAL DEMANDED
 Core Scientific, Inc. and                     §
 CoreWeave, Inc.                               §
                                               §
                   Defendants.                 §
                                               §
 Core Scientific, Inc.,                        §
                                               §
                   Defendant and Third-Party   §
                   Plaintiff,                  §
                                               §
        v.                                     §
                                               §
 CoreWeave, Inc.                               §
                                               §
                   Third-Party Defendant.      §


       REPLY IN SUPPORT OF CORE SCIENTIFIC, INC.’S MOTION TO DISMISS
              PURSUANT TO FED. R. CIV. P. 12(b)(6) AND 35 U.S.C. § 101


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                                        TABLE OF CONTENTS


 I.    The 960 and 062 Patent Claims Fail Both Alice Steps Under Plaintiffs’ Analysis ................ 2

 II.   The 827 and 370 Patent Claims Fail Both Alice Steps Under Plaintiffs’ Analysis ................ 5

 III. The 286 Patent Claims Fail Both Alice Steps Under Plaintiffs’ Analysis .............................. 9


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                                                  TABLE OF AUTHORITIES


 Alice Corp. Pty. v. CLS Bank Int’l, 573 U.S. 208 (2014) ..................................................... 4, 8, 10

 BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281 (Fed. Cir. 2018) ............................................. 8

 ChargePoint, Inc. v. SemaConnect, Inc., 920 F.3d 759 (Fed. Cir. 2019) ................................. 5, 10

 Diamond v. Diehr, 450 U.S. 175 (1981) ......................................................................................... 7

 Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344 (Fed. Cir. 2014) ......... 6, 7

 Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016)......................................... 4, 5, 10

 In re Board of Trs. of Leland Stanford Junior Univ., 989 F.3d 1367 (Fed. Cir. 2021) ......... passim

 In re Board of Trs. of Leland Stanford Junior Univ., 991 F.3d 1245 (Fed. Cir. 2021) .................. 9

 Infernal Tech., LLC v. Sony Interactive Ent. LLC, No. 2:19-CV-00248-JRG, 2021 WL

    5804262 (E.D. Tex. Dec. 7, 2021) .............................................................................................. 4

 Intell. Ventures I LLC v. Cap. One Bank (USA), 792 F.3d 1363 (Fed. Cir. 2015) ..................... 5, 7

 Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335 (Fed. Cir. 2018) ........................................... 6

 Optis Cellular Tech. LLC v. Apple Inc., 139 F.4th 1363 (Fed Cir. 2025) ...................................... 7

 Parker v. Flook, 437 U.S. 584 (1978).................................................................................... passim

 PersonalWeb Tech. LLC v. Google LLC, 8 F.4th 1310 (Fed. Cir. 2021) ............................... passim

 RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322 (Fed. Cir. 2017) ........................................ 3, 7

 SAP America, Inc. v. Investpic, LLC, 898 F.3d 1161 (Fed. Cir. 2018) ............................. 1, 3, 5, 10

 Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138 (Fed. Cir. 2016) ......................... 3, 7, 10

 TQP Dev., LLC v. Intuit Inc., No. 2:12–CV–180–WCB, 2014 WL 651935 (E.D. Tex.

    Feb. 19, 2014) ............................................................................................................................. 8

 Trinity Info Media, LLC v. Covalent, Inc., 72 F.4th 1355 (Fed. Cir. 2023) ............................. 2, 10

 Univ. of Fla. Research Found., Inc. v. GE Co., 916 F.3d 1363 (Fed. Cir. 2019) ........................... 6


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                                TABLE OF ABBREVIATIONS


  Malikie Innovations Ltd. and Key Patent Innovations Ltd.                     Plaintiffs
  Core Scientific, Inc.                                                        Core Scientific
  Core Scientific’s Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(b)(6)     Mot.
  and 35 U.S.C. § 101 (Dkt. 114)
  Plaintiffs’ Opposition to Core Scientific’s Motion to Dismiss (Dkt. 119)     Opp.
  U.S. Patent No. 7,372,960                                                    960 patent
  U.S. Patent No. 8,666,062                                                    062 patent
  U.S. Patent No. 8,788,827                                                    827 patent
  U.S. Patent No. 10,284,370                                                   370 patent
  U.S. Patent No. 8,532,286                                                    286 patent
  960, 062, 827, 370, and 286 patents                                          Challenged Patents


                                           EMPHASIS

 All emphasis added unless otherwise specified


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         Mathematical algorithms, no matter how novel or groundbreaking they may be, are not

 ineligible for patent protection because they are part of the “basic tools of scientific and

 technological work.” Parker v. Flook, 437 U.S. 584, 591-92 (1978). At bottom, whatever novelty

 there may be in the claims of the Challenged Patents is found only in the algorithms. And a claim

 that is “directed essentially to a method of calculating, using a mathematical formula, even if the

 solution is for a specific purpose, … is nonstatutory.” Id. at 595.

         Plaintiffs’ arguments to the contrary, asserted in both the FAC and again in the

 Opposition, do not compel a different conclusion. Repeated references to the claims being

 directed at “technological solutions” to “technological problems” are unavailing because those

 alleged “technological solutions” are the algorithms themselves. That is not enough to avoid

 invalidity under § 101. Parker, 437 U.S. at 595, n.18 (“Very simply, our holding today is that a

 claim for an improved method of calculation, even when tied to a very specific end use, is

 unpatentable subject matter under § 101.”); SAP America, Inc. v. Investpic, LLC, 898 F.3d 1161,

 1163 (Fed. Cir. 2018) (“The claims here are ineligible because their innovation is an innovation

 in ineligible subject matter.”).

         Plaintiffs’ attempts to avoid dismissal by reference to alleged factual and claim

 construction disputes also must fail. Even if the inventions described in the patents were

 groundbreaking and resulted in more efficient calculating, that does not change what is specified

 in the claims—improved mathematical algorithms. PersonalWeb Tech. LLC v. Google LLC, 8

 F.4th 1310, 1319 (Fed. Cir. 2021) (rejecting argument that “improvements [described] in the

 specification” prevented dismissal because the claims lacked an “inventive concept in the non-

 abstract application realm”). As to claim construction, Plaintiffs have failed to show how

 construction of the few terms they identify would impact the understanding of the claims. Trinity


                                                   1


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 Info Media, LLC v. Covalent, Inc., 72 F.4th 1355, 1360-61 (Fed. Cir. 2023). Consequently, the

 Court should grant Core Scientific’s Motion to Dismiss.

 I.     The 960 and 062 Patent Claims Fail Both Alice Steps Under Plaintiffs’ Analysis

        ACS concedes that the only claims from these patents that it is asserting are claims 3 and

 6 of the 960 patent and claims 1-4, 6, and 7 of the 062 patent. Opp. at 14, n.7. Thus, independent

 claim of the 960 patent is indeed representative. Mot. at 14-16. 1 The only difference between

 claim 3 and independent claim 1 of the 062 patent is th at the latter is written in terms of a

 processor executing the instructions making up the algorithm. 2

        Claim 3 of the 960 patent is unquestionably directed to an algorithm. The claimed steps

 take an input (step a), perform mathematical operations on the input to obtain a first result (steps

 b and c), perform further mathematical operations on that result to obtain a second result (step d),

 and use the second result in a cryptographic operation (step e). 960 patent, claim 3. There is no

 material difference between claim 3 and the claim invalidated in Parker, which similarly

 performed mathematical operations on an input to obtain a result (an “updated alarm limit”) for

 use in a particular field (a “process involving the catalytic chemical conversion of

 hydrocarbons”). 437 U.S. at 596-97 (listing claim). Nor is there a material difference between

 claim 3 and the claim invalidated in Stanford I. That claim also performed mathematical

 operations on an input (“allele information regarding genotypes”) to obtain a result (“a haplotype


 1
         Core Scientific reserves the right to challenge any non-asserted claims as part of an
 invalidity counterclaim if its motion to dismiss is not granted.
 2
         Plaintiffs’ dependent claims argument is not persuasive. Reviewing claims 6 of the 960
 patent and claims 2-4, 6 and 7 of the 062 patent shows that they merely add further details
 regarding the algorithm, such as the inputs to the algorithm (062, claims 2, 3), the makeup and
 role of the finite field in the algorithm (960 claim 6, 062 claim 4), and the field of use (062,
 claims 6, 7). These claims do not add “significantly more” to the abstract idea. In re Board of
 Trs. of Leland Stanford Junior Univ., 989 F.3d 1367, 1372 (Fed. Cir. 2021) (“Stanford I”).
                                                   2


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 phase for at least member of the family”), storing it in computer memory, and providing the

 haplotype phase upon request. 989 F.3d at 1370.

        Claim 3 and those in Parker and Stanford I are directed to “mathematical algorithms for

 performing calculations,” which “without more, are patent ineligible.” Id. at 1372; see

 RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327 (Fed. Cir. 2017) (“A process that

 started with data, added an algorithm, and ended with a new form of data was directed to an

 abstract idea.”). That holds true here. There is nothing “more” in claim 3. That the claim requires

 that the result be “used” in a “cryptographic operation” is of no moment because specifying that

 the result is “for a specific purpose” cannot save the claim if the claim is “directed essentially to

 a method of calculating, using a mathematical formula.” Parker, 437 U.S. at 595.

        Plaintiffs argue that the claim is a technological solution to a technical problem. Even

 taken as true for argument’s sake, that does not save the claims because the “technological

 solution” is the algorithm itself. It matters not whether the algorithm is novel or groundbreaking.

 In Stanford I, Stanford asserted that the claimed invention was “novel” and enabled scientists to

 “ascertain more haplotype information than was previously possible.” 989 F.3d at 1373. But

 even “accepting the argument that the claimed process results in improved data, we are not

 persuaded that claim 1 is not directed to an abstract mathematical calculation.” Id., citing

 Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“[A] claim for a

 new abstract idea is still an abstract idea”); SAP, 898 F.3d at 1170 (“[P]atent law does not protect

 such claims, without more, no matter how groundbreaking the advance.”). Here, claim 3 covers

 at most a “new abstract idea.”

        Nor does claim 3 improve the functioning of computers, as Plaintiffs allege. There is

 nothing in the claims or the patents that improves computer functioning per se. The 960 patent


                                                   3


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 confirms that it uses generic processors and memory. 960 patent, 6:46-48. Instead, the alleged

 improvement is the “specialized reduction algorithms.” Id. at 7:43-45. But even if an algorithm

 results in a faster or more efficient way to obtain the claimed reduced result of a finite field,

 faster or better algorithms are still abstract ideas. At most, the claims merely “enhance[] an

 ineligible concept;” they are not “improvement[s] on a technological process.” Stanford I, 989

 F.3d at 1373; PersonalWeb, 8 F.4th at 1316 (“The claims do this in a computer environment, but

 that doesn’t transfigure an idea out of the realm of abstraction”). 3 As in PersonalWeb, whether

 the algorithm results in a more efficient process on a computer does not “render an abstract idea

 less abstract.” Id. at 1319. The focus of the claims here is “not on … an improvement in

 computers as tools, but on certain independently abstract ideas that use computers as tools,” and

 that “fails [Alice 4] step one.” Id.

         The claims here, contrary to Plaintiffs’ arguments, are not like those in Enfish, LLC v.

 Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016), and Infernal Tech., LLC v. Sony Interactive

 Ent. LLC, No. 2:19-CV-00248-JRG, 2021 WL 5804262 (E.D. Tex. Dec. 7, 2021). In Enfish, the

 claims required “a data storage and retrieval system for a computer memory” with “a self-

 referential table for a computer database.” 822 F.3d at 1336–37. Therefore, the claimed table “is

 a specific type of data structure designed to improve the way a computer stores and retrieves

 data in memory.” Id. at 1339. Similarly, in Infernal Tech., the claimed process “actually


 3
         Plaintiffs’ claim construction argument also fails. Plaintiffs assert that the terms “machine
 words” and “wordsized operation” show that the claims are intended to be performed on a
 computer. Opp. at 9-11. Even if true, an algorithm performed on a generic computer is still
 patent ineligible. Stanford I, 989 F.3d at 1374 (“[C]laim 1 neither requires, nor results in, a
 specialized computer with a specialized memory or processor.”). That applies here.
 4
         Alice Corp. Pty. v. CLS Bank Int’l, 573 U.S. 208 (2014).


                                                   4


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 improves graphics rendering in computers” and thus is “an improvement to the functionality of

 computers in rendering realistic graphics.” 2021 WL 5804262, at *4. Thus, the claimed

 technology in Enfish and Infernal Tech. are “improvement[s] to computer functionality itself,”

 Enfish, 822 F.3d at 1336. Claim 3, in contrast, is an alleged improved algorithm for finite field

 calculations; it does not improve a computer’s ability to perform any other tasks. “[O]ur

 precedent is clear that merely adding computer functionality to increase the speed or efficiency

 of the process does not confer patent eligibility on an otherwise abstract idea.” Intell. Ventures I

 LLC v. Cap. One Bank (USA), 792 F.3d 1363, 1370 (Fed. Cir. 2015).

        Turning to Alice step two, the Federal Circuit’s analysis in PersonalWeb is apt here:

 “[w]hat else is there in the claims before us? … As to the subject-matter question, not much.” 8

 F.4th at 1319. There is “nothing ‘inventive’ about any claim details, individually or in

 combination, that are not themselves abstract ideas.” Id. Again, whether the claimed algorithm

 is novel is not relevant because the claimed “innovation is an innovation in ineligible subject

 matter.” SAP, 898 F.3d at 1163. And “[t]hat fails step two.” PersonalWeb, 8 F.4th at 1319. 5

        Accordingly, the asserted claims of the 960 and 062 patents fail both steps of the Alice

 inquiry because they recite abstract, mathematical operations that are patent-ineligible.

 II.    The 827 and 370 Patent Claims Fail Both Alice Steps Under Plaintiffs’ Analysis

        Plaintiffs’ arguments for the 827 and 370 patents also fail, as, at most, the claims are


 5
         Whether in step one or two, Plaintiffs’ arguments regarding the specification cannot save
 the claims. The specification “cannot be used to import details from the specification if those
 details are not claimed.” ChargePoint, Inc. v. SemaConnect, Inc., 920 F.3d 759, 769 (Fed. Cir.
 2019). The alleged improvements of eliminating the need for “duplicating the bulk of the engine
 instructions (program)” and “finite field elements [that can] be consistently stored in registers of
 the same word length,” Opp. at 5–6, are not claimed. Alleging improvements that are stated in
 the specification and not claimed cannot defeat a motion to dismiss. PersonalWeb, 8 F.4th at
 1319 (rejecting the same argument Plaintiffs make here).
                                                   5


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 directed to an improved digital signature verification algorithm and nothing “more.” 6 Claim 1 of

 the 827 patent recites 3 steps: (1) “receiving” a signature without a public key from a message;

 (2) “obtaining” an elliptic curve point from the signature; and (3) “generating” a public key of

 the signer from the elliptic curve point and a hash value of the message. These types of process

 steps have repeatedly been found abstract. Univ. of Fla. Research Found., Inc. v. GE Co., 916

 F.3d 1363, 1367 (Fed. Cir. 2019) (collecting cases finding steps such as collecting, analyzing,

 manipulating, and displaying data abstract).

        As Plaintiffs acknowledge, the alleged improvement instead lies in recovering the public

 key Q from the signature itself using the formula 𝑄𝑄 = 𝑟𝑟 −1 (𝑠𝑠𝑠𝑠 − 𝑒𝑒𝑒𝑒). Opp. at 18-19. Once again,

 the mathematical formula—the algorithm—is the focus of the claim. That is not enough.

 Digitech Image Techs., LLC v. Elecs. for Imaging, Inc., 758 F.3d 1344, 1351 (Fed. Cir. 2014)

 (“[A] process that employs mathematical algorithms to manipulate existing information to

 generate additional information is not patent eligible”); Parker, 437 U.S. at 595.

        Plaintiffs again argue about the claim being a technological solution to a technological

 problem. Opp. at 17–19. But like the analysis for the 960 and 062 patents, even accepting that as

 true for purposes of this motion, the alleged improvement here is to the pre-existing Elliptic

 Curve Digital Signature Algorithm (ECDSA) itself: recovering the public key for faster

 verification. 827 patent, 4:16-27 (stating that “improvement of ECDSA verification time is

 important”); 5:63-65 (“The present invention is exemplified by reference to verification of digital


 6
         Here too, Plaintiffs concede that only claims 1-5 of each patent are asserted. Opp. at 18,
 n.11, 24, n. 16. Claim 1 of the 827 patent is thus representative of the claims. Claim 1 of the 370
 patent contains the same algorithmic steps and merely adds generic “processor,” “computing
 device,” and “network” hardware, which the Federal Circuit has repeatedly found cannot render
 a claim non-abstract. Interval Licensing LLC v. AOL, Inc., 896 F.3d 1335, 1345 (Fed. Cir. 2018).
 Dependent claims 2-5 in each patent are identical and only add additional details concerning the
 algorithm itself or its field of use. Mot. at 21-22.
                                                   6


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 signatures, in particular those signatures generated using ECDSA”). And a “claim for a new

 abstract idea is still an abstract idea.” Synopsys, 839 F.3d at 1151. Unlike in Enfish, the claims

 here do not improve the functionality of the computer itself. Stanford I, 989 F.3d at 1374

 (“[C]laim 1 neither requires, nor results in, a specialized computer with a specialized memory or

 processor.”); Intell. Ventures, 792 F.3d at 1370 (holding that increasing the “speed or efficiency

 of the process does not confer patent eligibility on an otherwise abstract idea”). 7

        Plaintiffs’ argument that ECDSA is computer-centric technology does not change the

 outcome. PersonalWeb, 8 F.4th at 1316 (“The claims do this in a computer environment, but that

 doesn’t transfigure an idea out of the realm of abstraction”); Optis Cellular Tech. LLC v. Apple

 Inc., 139 F.4th 1363, 1380 (Fed Cir. 2025) (“[T]he claims are directed to reciting an equation

 that outputs a value to be used as the specific start position for decoding information in a cellular

 network. This is an ineligible mathematical formula.”); Digitech, 758 F.3d at 1351 (holding that

 “a process that employs mathematical algorithms to manipulate existing information to generate

 additional information is not patent eligible.”). There is nothing “more” in the claims here other

 than applying the allegedly improved algorithm to input data to obtain output data (a public key).

 The claims are thus directed at a patent-ineligible mathematical algorithm. Parker, 437 U.S. at

 595; see RecogniCorp, 855 F.3d at 1327 (finding that a process that, like here, “started with data,

 added an algorithm, and ended with a new form of data” is an abstract idea).

        Plaintiffs’ reliance on Diamond v. Diehr, 450 U.S. 175 (1981) is off-base. Those claims

 were directed to transforming “raw, uncured synthetic rubber, into a different state” and the

 applicants sought “patent protection for a process of curing synthetic rubber.” Id. at 184–87.


 7
         The claimed invention uses only “general purpose computers connected to a network or
 specialized devices such as cell phones, pagers, PDA’s, or the like.” 827 patent, 6:16-20.
                                                   7


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 Thus, the claims were directed to an “industrial process.” Id. at 191–93. The claims here are not

 remotely similar. Instead, “[t]he sole practical application of the algorithm [(i.e., the claimed

 improved version of the ECDSA] was in connection with the programming of a general purpose

 digital computer… which cannot be the subject of a patent.” Id. at 185–86.

        TQP Dev., LLC v. Intuit Inc., No. 2:12–CV–180–WCB, 2014 WL 651935 (E.D. Tex.

 Feb. 19, 2014) does not hold otherwise. The claims in TQP were patent eligible, not because the

 claims are in the field of data encryption, but because they “involve[] a way of making computer

 communication itself more effective by making that communication more secure.” 2014 WL

 651935, at *7. The claimed improvement here is not to the computer itself but is an alleged

 improvement to an algorithm (ECDSA) that merely invokes computers as a tool.

        As for Alice step two, Plaintiffs merely reiterate the background and the claimed

 advantage of the invention and conclude that the claim “covers a patent-eligible inventive

 concept.” Opp. at 22-23. But reviewing claim 1 reveals that other than the allegedly improved

 ECDSA for recovering the public key, there are no “additional features” to “transform the

 claimed abstract idea into a patent-eligible application.” Alice, 573 U.S. at 221. Indeed, the

 entirety of the claim is the algorithm, and as such it fails step two as a matter of law. “[T]he

 relevant inquiry is not whether the claimed invention as a whole is unconventional or non-

 routine,” but “whether the claim limitations other than the invention’s use of the ineligible

 concept to which it was directed were well-understood, routine and conventional.” BSG Tech

 LLC v. Buyseasons, Inc., 899 F.3d 1281, 1290 (Fed. Cir. 2018). Here, there are simply no claim

 limitations beyond the algorithm’s application to the input data to produce the public key. 8


 8
        Plaintiffs make no arguments that claim construction is required and thus have waived
 any such argument.
                                                   8


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        Accordingly, the asserted claims of the 827 and 370 patents fail both steps of the Alice

 inquiry because they recite abstract, mathematical operations not eligible for patent protection.

 III.   The 286 Patent Claims Fail Both Alice Steps Under Plaintiffs’ Analysis

        Claim 1 of the 286 patent is not materially different from all the claims analyzed above: it

 claims an improved way of performing a Montgomery-style reduction mathematical algorithm.

 Claim 1 9 contains 3 steps: (1) obtaining an operand; (2) computing a modified operand using a

 reduction value; and (3) outputting the modified operand. The computing step involves the

 alleged improvement to the standard Montgomery reduction algorithm. This is another example

 of a non-eligible improvement to an abstract idea, as admitted in the patent itself. 286 patent,

 3:21-22 (the objective of the invention is “[t]o improve the reduction efficiency of a

 Montgomery machine”). Such an improvement “does not qualify as an improvement to a

 technological process” but rather is “an enhancement to the abstract mathematical calculation []

 itself.” In re Board of Trs. of Leland Stanford Junior Univ., 991 F.3d 1245, 1251 (Fed. Cir.

 2021). Even assuming the claimed improved algorithm “yields different or better results,” it is

 still a mathematical algorithm and “does not render [the claim] patent eligible.” Id.

        Plaintiffs cite the specification in arguing that the claim describes “how a computer

 performs a new kind of Montgomery-style reduction,” which is an alleged technological

 improvement. Opp. at 26–28. Plaintiffs assert that the improvement “can reduce the number of

 computations and registers needed” and the improved method makes it convenient to perform

 modified reduction in some known computer architectures. Id. Even accepting that is true, first,

 an “improved mathematical analysis” (i.e., reduced number of computations) is not patentable


 9
          Plaintiffs concede that only claim 1 and dependent claims 5, 6, and 9 are asserted. Opp. at
 30. Claim 1 is therefore plainly representative, as the dependent claims add only features directed
 to the field of use (claims 5, 6) or the type of calculation used (claim 9). Mot. at 27-28.
                                                  9


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 subject matter. SAP, 898 F.3d at 1168. Second, “[t]he § 101 inquiry must focus on the language

 of the Asserted Claims themselves.” Synopsys, 839 F.3d at 1149, and details from the

 specification cannot be imported into the claims. ChargePoint, 920 F.3d at 769. Here, claim 1

 has none of the alleged technological improvements. Plaintiffs’ analogy to Enfish is again

 unpersuasive because while the claims there “improve the way a computer stores and retrieves

 data in memory,” 822 F.3d at 1339, the claims here, as Plaintiffs tacitly admit, only recite an

 improved mathematical algorithm implemented on a generic computer. Opp. at 27-28; see

 Trinity, 72 F.4th at 1362-63. Once again, a new and improved algorithm executed on a generic

 computer is still non-eligible. Synopsys, 839 F.3d at 1151 (“[A] claim for a new abstract idea is

 still an abstract idea”). Claim 1 covers at most a “new abstract idea,” and thus fails step one. 10

        For step two, Plaintiffs again make conclusory statements that the claim recites an

 inventive concept. But they fail to identify any “additional features” to “transform the claimed

 abstract idea into a patent-eligible application.” Alice, 573 U.S. at 221. There is “not much” else

 in the claim other than the abstract idea, which fails step two. PersonalWeb, 8 F.4th at 1319; see

 Stanford I, 989 F.3d at 1373-74 (holding that “simply storing information and providing it upon

 request” does not transform the abstract idea into eligible subject matter).

        Accordingly, the asserted claims of the 286 patent fail both steps of the Alice inquiry

 because they recite abstract, mathematical operations not eligible for patent protection.


 10
         Plaintiffs identify “least significant word” and “word” as terms that may require
 construction, but fail to propose any constructions, and fail to explain how constructions would
 change the analysis. Opp. at 27-28. The 286 patent concedes that the invention may be
 “implemented as an apparatus in hardware or in software (computer readable instructions
 embodied in/on a computer readable medium).” 286 patent, 4:2-5. At bottom, claim construction
 will not matter because, even assuming the claim is directed at computer-based technology, “an
 abstract idea does not become nonabstract by limiting the invention to a particular field of use or
 technological environment.” Recentive Analytics, Inc. v. Fox Corp., 134 F.4th 1205, 1213 (Fed.
 Cir. 2025).
                                                   10


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    Dated: July 15, 2026                  Respectfully submitted,
                                          /s/ Brian E. Ferguson
                                          Brian E. Ferguson
                                          KING & SPALDING LLP
                                          1700 Pennsylvania Avenue, NW
                                          Suite 900
                                          Washington, D.C. 20006
                                          Telephone: (202) 737-0500
                                          Email: [email protected]

                                          Rex A. Mann
                                          Texas Bar No. 24075509
                                          KING & SPALDING LLP
                                          2601 Olive Street
                                          Suite 2300
                                          Dallas, TX 75201
                                          Tel.: (214) 764-4600
                                          Email: [email protected]

                                          John Tyler Boyce
                                          Texas Bar No. 24127214
                                          KING & SPALDING LLP
                                          1100 Louisiana, Suite 4100
                                          Houston, TX 77002
                                          Tel.: (713) 276-7324
                                          Email: [email protected]

                                          Attorneys for Core Scientific, Inc.


                                     11


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                                 CERTIFICATE OF SERVICE

        I certify that a true and correct copy of the foregoing document has been served on
 counsel of record, who are deemed to have consented to electronic service, on July 15, 2026, via
 electronic filing using the Court’s CM/ECF system.

                                             /s/ Brian E. Ferguson

                                             Brian E. Ferguson


                                                12