In AGI SureTrack LLC v. Farmers Edge Inc., Nos. 2024-1730, 2024-1830 (Fed. Cir. June 2, 2026), the Federal Circuit affirmed a district court’s summary judgment that asserted claims directed to a relay device for tracking farming operations were patent-ineligible under 35 U.S.C. § 101, while separately vacating the district court’s sua sponte denial of attorney’s fees under 35 U.S.C. § 285 and remanding for further consideration.
Applying the two-step Alice framework, the Federal Circuit agreed that representative claim 1 of U.S. Patent No. 11,126,937was directed to an abstract idea at step one. The Federal Circuit reiterated that claims reciting generalized steps of collecting, analyzing, and presenting information using nothing more than generic computer components are directed to abstract ideas, and that limiting such claims to a particular type of data, here farming data, does not remove them from the realm of abstraction. Although AGI argued that its claims covered a specific method of collecting and interpreting, in real time, data from a variety of farm-equipment brands using incompatible encoding and transmission rules, the Federal Circuit found that the specification did not describe any specific improvement in computer functionality tied to the claimed system. At Alice step two, the Federal Circuit held that the claims relied on generic computer components used in a conventional manner, and that an improvement in speed attributable merely to the use of a computer was insufficient to supply an inventive concept.
Addressing Farmer’s cross-appeal, the Federal Circuit took a different view of the fee ruling. Farmers Edge had argued the case was exceptional based on alleged inequitable conduct, misleading statements regarding abandonment of certain claims, unsupported assertions about factual disputes over eligibility, and violations of court-issued protective orders. The Federal Circuit observed that, under most circumstances, a district court should provide some reasoning for an exceptionality determination to permit meaningful appellate review for abuse of discretion. Because the district court’s sua sponte denial lacked such analysis, the Federal Circuit vacated that decision and remanded with instructions to reassess the issue after giving the parties an opportunity to present argument. The Federal Circuit further noted that, although a motion for attorney’s fees is due within fourteen days of judgment, a new fourteen-day period begins when a new judgment is entered following reversal or remand by an appellate court.
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