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Patent Subject Matter Eligibility

Federal Circuit
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Illumina v. Ariosa Diagnostics — Federal Circuit Upholds Prenatal DNA Method Patent as Eligible, Distinguishing Mayo

The Federal Circuit reversed a district court ruling and held that method-of-preparation claims for enriching cell-free fetal DNA from maternal blood were patent eligible under § 101, because the claims went beyond merely observing a natural phenomenon and recited concrete preparation steps.

Federal Circuit
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American Axle v. Neapco Holdings — Federal Circuit Holds Driveshaft Manufacturing Method Claims Ineligible Under Hooke’s Law

The Federal Circuit held that patent claims directed to manufacturing driveshaft liners that “attenuate” vibrations were invalid under § 101 because they were simply an instruction to apply Hooke’s law — a natural law — without specifying how to do so, triggering a sharp dissent warning of § 101 ove

Federal Circuit
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Chamberlain Group v. Techtronic Industries — Federal Circuit Invalidates Wireless Garage Door Sensor Patents Under § 101

The Federal Circuit invalidated garage door opener patents covering a wireless sensor system for communicating door state, holding the claims were directed to the abstract idea of wirelessly communicating status information — an idea that cannot be its own inventive concept.

Federal Circuit
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Solutran, Inc. v. Elavon, Inc. — Federal Circuit Holds That Physical Check Processing Steps Do Not Save Abstract Business Method from § 101

The Federal Circuit reversed a district court and invalidated Solutran’s check-processing patent under § 101, holding that the presence of physical steps involving paper checks does not transform an abstract business method into patent-eligible subject matter.

Federal Circuit
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Cellspin Soft v. Fitbit — Federal Circuit Applies Berkheimer to Deny Motion to Dismiss on § 101 Grounds

The Federal Circuit reversed a district court’s dismissal of patent claims as ineligible under § 101, applying Berkheimer to hold that well-pleaded factual allegations about how the claimed invention was an unconventional advance must be accepted as true at the 12(b)(6) stage — limiting early

Federal Circuit
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Endo Pharmaceuticals Inc. v. Teva Pharmaceuticals USA, Inc. — Federal Circuit Holds Specific Dosing Method for Renally Impaired Patients Is Patent Eligible

The Federal Circuit reversed a district court’s ruling that Endo’s oxymorphone dosing patent was ineligible, holding that claims directed to a specific method of treating specific patients with specific dosages are not merely abstract natural laws.

Federal Circuit
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Natural Alternatives International, Inc. v. Creative Compounds, LLC — Federal Circuit Holds Beta-Alanine Supplement Patents Are Eligible as Unnatural-Quantity Treatment Claims

The Federal Circuit reversed a district court’s ruling that patents on using beta-alanine as a dietary supplement were invalid under § 101, holding that method of treatment claims covering use of a natural compound in non-naturally-occurring quantities to alter physiology are patent eligible.

Federal Circuit
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Athena Diagnostics v. Mayo Collaborative Services — Federal Circuit Invalidates MuSK Diagnostic Patent, Splits Sharply on § 101 Reform

The Federal Circuit invalidated a diagnostic patent for detecting autoantibodies linked to myasthenia gravis, then denied en banc rehearing in a rare decision accompanied by eight separate opinions, exposing the court’s deep division over § 101 and diagnostic patents.

Federal Circuit
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Trading Technologies v. IBG — Federal Circuit Finds Futures Trading Interface Patents Ineligible as Abstract Ideas

The Federal Circuit held that Trading Technologies’ patents on a graphical user interface for electronic futures trading were patent-ineligible abstract ideas under Alice — finding that displaying market data and allowing traders to place orders by clicking on a price ladder represented an abs

Federal Circuit
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Ancora Technologies, Inc. v. HTC America, Inc. — Federal Circuit Holds BIOS-Based Software License Verification Patent Is Eligible Under § 101

The Federal Circuit reversed a district court’s dismissal and held that a patent claiming a method of preventing computers from running unlicensed software by using the BIOS to store a license verification key is not an abstract idea—it claims a concrete improvement to computer security functionalit

Federal Circuit
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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.

Federal Circuit
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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.

Federal Circuit
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Berkheimer v. HP Inc. — Federal Circuit Holds Patent Eligibility Step 2B Contains Factual Questions Not Resolvable on Summary Judgment

The Federal Circuit held that the Alice/Mayo Step 2B inquiry — whether a claim element or combination of elements represents an ‘inventive concept’ that was well-understood, routine, and conventional — contains underlying factual questions that may not always be resolved as a matter of l

Federal Circuit
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Finjan v. Blue Coat Systems — Federal Circuit Requires Further Apportionment of Damages for Multi-Feature Software Products

The Federal Circuit held that identifying the “smallest salable patent-practicing unit” is not sufficient when that unit still contains non-patented features, and further apportionment is required to isolate the value of the patented technology in complex software products.

Federal Circuit
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Credit Acceptance Corp. v. Westlake Services — Federal Circuit Affirms CBM Review Cancellation of Auto Finance Patent

The Federal Circuit affirmed PTAB’s cancellation of Credit Acceptance’s patent on financing automobile purchases through a dealer-administered program, holding the claims directed to the abstract idea of processing financing transactions — a business practice not rendered patent-eligible

Federal Circuit
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Smart Systems Innovations v. Chicago Transit Authority — Federal Circuit Holds Open Transit Payment Patents Abstract Under Section 101

The Federal Circuit affirmed invalidity of Smart Systems’ open-loop transit payment patents under Section 101, holding that collecting financial data using generic components to facilitate transit access is an abstract idea — with a notable dissent arguing that the claims addressed a real, Int

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