Sterlington successfully represented digital advertising technology company Teads in securing the dismissal of a patent infringement lawsuit brought by Yieldmo, Inc. The case – Yieldmo, Inc. v. Teads, Inc., Teads SA, and Teads SARL – was resolved in favor of Sterlington's client on July 21, 2025, when the U.S. District Court for the Southern District of New York held that the patents asserted by Yieldmo were invalid under 35 U.S.C. § 101.
Docket Navigator selected the ruling as its "Order of the Day," emphasizing the decision's resonance across the patent bar. Sterlington partner Brent Babcock served as lead counsel in the matter. Brent is widely recognized for his work in high-stakes patent litigation and has a track record of resolving disputes at the pleading stage.
Background
Yieldmo, a U.S.-based digital advertising company, filed suit against Teads and its affiliated entities, alleging infringement of four patents. The patents concerned technology for delivering mobile advertisements that respond dynamically to user interactions – specifically, scroll-based triggers that adjust ad display in real time.
Yieldmo claimed that its patented methods improved digital advertising by allowing for greater interactivity and user engagement. Teads, represented by Sterlington, moved to dismiss the case, arguing that the asserted patents were directed to abstract ideas and therefore invalid under the Patent Act.
The Court's Decision
Judge Paul A. Engelmayer granted Teads's motion to dismiss in full. The Court found that the patents were directed to patent-ineligible subject matter. It concluded that the core idea, customizing advertising content in response to user activity, was too abstract to qualify for patent protection.
The Court also rejected Yieldmo's argument that the patents disclosed a technological improvement. Instead, it found that the claims merely described the use of conventional computing elements to execute a longstanding advertising concept in a digital format. The decision drew on extensive precedent invalidating similar patents in the targeted advertising and content customization space.
In particular, the Court viewed the patents' description of scrolling-based ad transitions as a generic implementation of known functionality and found no "inventive concept" that could render the claims patent-eligible.
A Strategic Win
This decision is significant for Teads and the broader AdTech industry. It reinforces that abstract concepts, even when framed in technical terms or implemented through software, must meet a high threshold of inventiveness to obtain patent protection. The ruling also highlights the strength of early dispositive motion practice in defending against patent assertions that lack substantive merit.