Background
AGI SureTrack LLC sued Farmers Edge Inc. and Farmers Edge (US) Inc. for infringement of five patents related to automated systems for capturing, processing, and sharing farming data. The district court granted summary judgment for Farmers Edge, holding the asserted claims were directed to patent-ineligible subject matter under Section one hundred and one of Title thirty-five of the United States Code and that the case was not exceptional for purposes of an award of attorney’s fees under Section two hundred and eighty-five.
The court’s reasoning
The court applied the two-step Alice framework. At step one, the court found the claims directed to the abstract idea of collecting, analyzing, and presenting information using generic computer components. The court rejected AGI’s argument that the claims solved an interoperability problem, noting the claims did not recite such a problem and merely added one abstract concept to another. At step two, the court found no inventive concept because the claims relied on conventional use of a microprocessor, bus connector, GPS receiver, and memory storage area. Regarding the cross-appeal, the court held that the district court’s terse ruling on exceptionality provided no basis for meaningful appellate review and was therefore an abuse of discretion.
What it means going forward
AGI’s patents are unenforceable as ineligible subject matter. Farmers Edge may seek attorney’s fees on remand, and the fourteen-day filing period for such a motion will restart upon entry of a new judgment.