Intellectual Ventures seemed to be closing in on a nice win in Maryland federal court a few months ago when a special master recommended that its patents on a mobile interface and managing XML documents be found eligible for protection under Section 101.

But that ruling was so May 2015. On Thursday, U.S. District Judge Paul Grimm of Maryland flipped the recommendation, citing more recent patent-eligibility case law from the U.S. Court of Appeals for the Federal Circuit and the district courts, paying special mention to U.S. District Judge Beth Labson Freeman of the Northern District of California and her recent decision involving Hewlett-Packard Co.