Opinions — Tuesday, June 2, 2026

The Federal Circuit affirmed the District of Nebraska's grant of summary judgment that claims of U.S. Patent Nos. 11,126,937, 10,963,825, 11,164,116, 11,361,261, and 11,507,899 asserted by AGI SureTrack LLC against Farmers Edge Inc. and Farmers Edge (US) Inc. are ineligible under 35 U.S.C. § 101, but vacated and remanded the district court's determination that the case was not exceptional under 35 U.S.C. § 285. The patents relate to automated systems for capturing, processing, and sharing farming data using passive data collection devices attached to farming equipment. Applying the two-step framework from Alice Corp. Pty. Ltd. v. CLS Bank Int'l, the court held at step one that the claims are directed to the abstract idea of collecting, analyzing, and presenting information using conventional computer components, rejecting AGI's argument that the claims address a specific interoperability problem between different brands of farm equipment or constitute an improvement in computer functionality. At Alice step two, the court found no inventive concept because the claims rely on generic computer components—a microprocessor, bus connector, GPS receiver, and memory storage area—used in a conventional manner, and the automation merely speeds up data collection without transforming the abstract idea into a patent-eligible application.

The decision reinforces that claims directed to data collection and analysis in a particular industry remain abstract even when narrowly tailored to specific subject matter, reaffirming the principle from BSG Tech LLC v. BuySeasons, Inc. that applying an abstract idea in a narrow way does not confer patent eligibility. The court's rejection of AGI's "implement profiles" argument—that using stored communication protocols to decode messages from farm equipment supplies an inventive concept—clarifies that using one dataset to interpret another dataset merely combines abstract concepts without sufficient transformation. On the exceptional case determination, the court held that district courts making exceptionality rulings under § 285 must generally "provide some indication of the reasoning underlying [their] decision to provide a basis for meaningful appellate review," citing Superior Fireplace Co. v. Majestic Prods. Co., and vacated because the district court's terse ruling without explanation or opportunity for argument prevented proper appellate review. The court also clarified that the fourteen-day period under Federal Rule of Civil Procedure 54(d)(2)(B) for filing fee motions runs anew following remand and entry of a new judgment.