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Patent Subject Matter Eligibility

Federal Circuit
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AGI SureTrack v. Farmers Edge — Federal Circuit Affirms Farming Data Patents Are Ineligible Under §101 but Reopens Attorney’s Fees Question

The Federal Circuit affirmed that patents claiming automated farming data collection using generic computer components are directed to patent-ineligible abstract ideas under Alice, but vacated the district court’s unexplained denial of attorney’s fees and remanded for further proceedings

Federal Circuit
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Constellation Designs v. LG Electronics — Federal Circuit Vacates § 101 Eligibility for Functional “Optimization” Claims, Affirms Eligibility for Specific Non-Uniform Constellation Claims

In a precedential opinion, the Federal Circuit drew a sharp § 101 line between functional ‘optimization’ claims that recite a result without specifying a concrete configuration and ‘constellation’ claims that recite specific non-uniform point arrangements. It vacated summary

Federal Circuit
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In re Hybir, Inc. — Federal Circuit Dismisses §101 Patent Eligibility Appeal as Moot Over $100 Settlement Side-Bet

The Federal Circuit dismissed a §101 patent eligibility appeal as moot after discovering the parties’ settlement agreement gave the defendant a $100 option to license the challenged patent — an amount so untethered from the patent’s value that it created no real case or controversy.

Federal Circuit
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Columbia University v. Gen Digital (Norton) — Federal Circuit Vacates $600M Patent Judgment, Finds Virus-Detection Claims Abstract Under Alice

The Federal Circuit vacated a $600 million patent infringement judgment against Norton (Gen Digital), holding that Columbia University’s computer virus-detection patent claims are directed to abstract ideas under Alice Step 1, and denied en banc rehearing.

Federal Circuit
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Chewy v. IBM — Federal Circuit Invalidates Web Advertising Patents Under § 101, Partially Reverses on Infringement

The Federal Circuit affirmed that IBM’s patent claims directed to identifying advertisements based on search queries are abstract ideas ineligible under § 101—using a conventional database to match ads with search results adds no inventive concept—while partially reversing on noninfringement,

Federal Circuit
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Sanderling Management v. Snap — Federal Circuit Invalidates Promotional Content Distribution Patents Under § 101

The Federal Circuit affirmed that patents claiming a method for distributing digital promotional content—loading branding images when a user’s GPS location matches a specified geographic area—are directed to the abstract idea of providing information based on meeting a condition, and contain n

Federal Circuit
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ChromaDex v. Elysium Health — Federal Circuit Holds Isolated Vitamin B3 Supplement Patent Invalid Under § 101

The Federal Circuit affirmed that patent claims directed to isolated nicotinamide riboside (NR)—a form of vitamin B3 found naturally in cow’s milk—are directed to a natural phenomenon and ineligible under § 101, because the claims effectively read on milk with only the isolation step as a diff

Federal Circuit
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International Business Machines Corp. v. Zillow Group, Inc. — Federal Circuit Holds Map-Based Property Display Patents Cover Abstract Ideas

The Federal Circuit affirmed that IBM’s patents covering coordinated map-based and list-based selection of geographic data were directed to the abstract idea of organizing and displaying visual information, lacking an inventive concept sufficient for patent eligibility.

Federal Circuit
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In re Killian — Federal Circuit Holds Social Security Benefit Eligibility Determination Is an Abstract Mental Process, Patent Ineligible Under § 101

The Federal Circuit affirmed rejection of claims covering a computer-implemented system for identifying Social Security Disability Insurance eligibility, holding the claims were directed to an abstract mental process that humans perform through observation and evaluation.

Federal Circuit
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CosmoKey Solutions GmbH v. Duo Security LLC — Federal Circuit Upholds Mobile Authentication Patent as Patent Eligible Under Alice Step Two

The Federal Circuit reversed a district court’s patent ineligibility ruling, holding that claims directed to a specific two-channel mobile authentication method that improves cybersecurity represent a concrete technical solution eligible for patent protection.

Federal Circuit
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Universal Secure Registry LLC v. Apple Inc. — Federal Circuit Holds Multi-Factor Authentication Coordination Patents Are Abstract Ideas Ineligible Under § 101

The Federal Circuit held that four patents covering methods for coordinating multi-factor authentication across secure registries, PINs, biometrics, and universal devices are directed to abstract ideas and lack an inventive concept sufficient to confer patent eligibility.

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