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Interval Licensing v. AOL — Federal Circuit Invalidates “Attention Manager” Display Patent as Claiming a Desired Result Without a Technical Solution

The Federal Circuit held that a patent covering an “attention manager” that displays content in unused screen space is ineligible under § 101, because it claims a desired outcome — non-interfering display of two information sets — without specifying any technical means of achieving it.

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Vanda Pharmaceuticals v. West-Ward Pharmaceuticals — Federal Circuit Upholds Patent Eligibility of Personalized Medicine Claims

The Federal Circuit held that method-of-treatment claims directed to a specific dosing regimen for schizophrenia based on a patient’s genetic profile are patent eligible under §101, distinguishing the Supreme Court’s Mayo decision and reinforcing the eligibility of personalized medicine patents.

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