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Coverage since July 23, 1998

Patent Subject Matter Eligibility

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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.

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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

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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

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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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