From Pleadings to Pour-Overs: The Federal Circuit Brews Up Clarity

Please join us on Monday, December 22, 2025, at noon for a discussion of two recent decisions made by the U.S. Court of Appeals for the Federal Circuit.

In Adnexus Inc. v. Meta Platforms, Inc., No. 24-1551 (Fed. Cir. 2025), Adnexus alleged that Meta’s Lead Ads product infringed a patent covering targeted online advertising by retrieving user profiles containing delivery method preferences, and supported its claims with detailed claim charts attached to its amended complaint. The district court dismissed the complaint with prejudice, finding that Adnexus failed to plausibly allege the required “delivery method preferences” limitation and dismissing related indirect and willful infringement claims. On review, the Federal Circuit vacated and remanded, holding that the district court improperly construed the disputed claim term against Adnexus at the motion to dismiss stage. Accepting the allegations as true, the court concluded that Adnexus plausibly alleged infringement.

In In re Bayou Grande Coffee Roasting Co., No. 24-1118 (Fed. Cir. 2025), the Federal Circuit considered whether the mark KAHWA is registrable for use with cafés and coffee shops. The application was refused registration because the mark was found to be generic or merely descriptive based on the alleged meanings of “coffee” in Arabic and as a type of Kashmiri green tea, and on the doctrine of foreign equivalents. The TTAB affirmed the refusal based solely on the Kashmiri green tea meaning. On appeal, the Federal Circuit reversed, holding that there was no substantial evidence that U.S. cafés or coffee shops sell kahwa. Therefore, the term is not generic or merely descriptive for the identified services. The court also concluded that the doctrine of foreign equivalents did not apply because KAHWA has an established English meaning.

Jonathan Gutierrez, associate at SoCal IP, will lead the discussion.