Delaware court splits patent-eligibility ruling in TQ Delta v. DISH
Judge Gregory Williams of the District of Delaware granted in part and denied in part DISH Network's Section 101 summary judgment motion in TQ Delta, LLC v. DISH Network Corp. (No. 15-614-GBW), opinion issued October 19, 2026.
On October 19, 2026, Judge Gregory Williams of the U.S. District Court for the District of Delaware granted in part and denied in part a motion for summary judgment under 35 U.S.C. § 101 in TQ Delta, LLC v. DISH Network Corp., No. 15-614-GBW. The material reviewed here is a single law-firm alert; it does not identify which claims or claim limitations were held eligible or ineligible, and the slip opinion itself is not in evidence, so the precise scope of the ruling should be confirmed against the opinion before it is relied on. At that level of generality, the development still matters to sophisticated patent counsel. Eligibility screening under § 101 is one of the most consequential early-stage levers in multiparty patent disputes, and a mixed ruling ordinarily keeps the case alive and pushes it toward claim construction, validity, and infringement rather than ending it on eligibility grounds alone. Clients on both sides of § 101 motions should track the resulting case-management schedule, the start of any claim-construction phase, and any notice of appeal, and should compare the court's reasoning with earlier eligibility rulings in the same litigation and with Delaware's evolving § 101 case law before adjusting prosecution, venue, or settlement strategy.