Court dismissed BProtocol patent case against Uniswap

A federal judge on February 10, 2026 dismissed a patent-infringement complaint brought by BProtocol Foundation and LocalCoin Ltd. against Universal Navigation Inc., which does business as Uniswap Labs, and the Uniswap Foundation. Judge John G. Koeltl of the U.S. District Court for the Southern District of New York held that the asserted claims in U.S. Patent Nos. 11,107,049 and 11,574,291 were directed to patent-ineligible abstract ideas and lacked the inventive concept required by the Supreme Court’s Alice framework.

The order removed an immediate legal threat to the organizations behind one of decentralized finance’s best-known exchange protocols. Its broader importance was more cautious: it showed how a court could evaluate blockchain and smart-contract patents using established software-patent doctrine. It did not declare automated market makers generally unpatentable, and it did not finally end the dispute on February 10. The dismissal was without prejudice, and the plaintiffs received 21 days to amend.

What the plaintiffs alleged

BProtocol and LocalCoin said their patents covered methods for exchanging and evaluating virtual currency. According to the amended complaint as summarized by the court, their claimed system used smart contracts, reserve assets and a pricing formula to support continuous liquidity, conversions and automated price discovery without a centralized exchange or an individual market maker. The plaintiffs alleged that Uniswap later developed a competing protocol that infringed those patents.

Those were allegations, not findings that Uniswap copied protected technology. At the motion-to-dismiss stage, the court accepted well-pleaded factual allegations as true while testing whether the complaint stated a legally sufficient claim.

Why the claims failed the Alice test

Koeltl applied the two-step test from Alice Corp. v. CLS Bank International. At step one, the court characterized the claims as the abstract idea of calculating currency-exchange rates to perform transactions. Collecting token-status information, applying a reserve-ratio constant and updating a ledger did not change that characterization.

Putting the exchange process on a blockchain was not enough. The opinion said the patents relied on pre-existing cryptocurrencies, smart contracts and blockchain systems, using that technology predictably to address an economic problem rather than claiming a technological improvement. At step two, the court found no additional inventive concept that transformed the abstract idea into a patent-eligible application. Features the plaintiffs described as innovative in their briefing could not rescue the patents when those features were not recited in the claims themselves.

The court also identified independent pleading defects. The amended complaint did not plausibly allege that Uniswap’s protocol contained the reserve-ratio constant required by the asserted claims. Koeltl noted that the plaintiffs had access to Uniswap’s open-source code yet did not identify that limitation in the code. The complaint also failed to plead the knowledge needed for induced or willful infringement; alleging awareness from the date the original lawsuit was filed was insufficient under the district’s cited precedent.

What changed on February 10

The verified development was a district-court dismissal of the entire amended complaint, not a trial verdict or an appellate rule binding every U.S. court. The order asked the clerk to enter judgment without prejudice and allowed an amended complaint within 21 days; absent one, the action would be dismissed with prejudice.

For protocol developers, the decision reduced the near-term force of these two patents against Uniswap and emphasized that economic formulas do not become patentable merely because smart contracts execute them. For patent holders, it underscored the need for claim language that identifies a specific technical improvement and for infringement allegations tied to every claimed limitation.

No price, volume or on-chain claim is warranted from the reviewed record. The court order establishes the legal event, but it does not establish any same-day effect on UNI, ether, decentralized-exchange liquidity or trading activity. As of February 10, the possibility of amendment—and therefore the ultimate posture of the case—remained unresolved.