Our Patent Case Summaries provide a weekly summary of the precedential patent-related opinions issued by the Court of Appeals for the Federal Circuit and the opinions designated precedential or informative by the Patent Trial and Appeal Board.
AGI SureTrack LLC v. Farmers Edge Inc., et al.
Nos. 2024-1730, -1830 (Fed. Cir. (D. Neb.) June 2, 2026). Opinion by Mayer, joined by Moore and Lourie.
AGI sued Farmers Edge for infringement of five patents related to automated systems and methods for capturing farming operation data in real time, and then processing and sharing the data. The district court granted Farmers Edge’s motion for summary judgment, holding that AGI’s patents were directed to patent-ineligible subject matter under 35 U.S.C. § 101. The court also determined that the case was not exceptional for purposes of an award of attorney’s fees under § 285. AGI appealed the § 101 determination, and Farmers Edge cross-appealed the holding that the case was not exceptional.
The Federal Circuit affirmed the patent-ineligibility determination. Starting with Alice step one, the Federal Circuit confirmed that the claims are directed to an abstract idea. The court ruled that “in explicit terms, the specification describes the claimed invention as a computer-implemented method for gathering and processing farming data.” The court also noted it has “frequently held [that] claims reciting generalized steps of collecting, analyzing, and presenting information, using nothing other than the conventional operations of generic computer components, are directed to abstract ideas.” That the claims here are limited to a particular type of information—farming data—“does not remove them from the realm of abstract.”
Next, under Alice step two, the court held that AGI’s claims “are directed to gathering and analyzing a particular type of data and do not disclose any specific inventive technology for performing those functions.” “They rely on generic computer components—such as a microprocessor, bus connector, GPS receiver, and memory storage area—which are used in a conventional manner to collect, analyze, and display data.” Thus, whether viewed individually or as an ordered combination, the Federal Circuit ruled that the claim elements “contain no inventive concept that would transform the abstract idea of collecting, interpreting, and transmitting data about farming operations into a patent-eligible application of that idea.”
Turning to the district court’s determination that the case was not exceptional under § 285, the Federal Circuit held that “there is nothing in the district court’s terse no exceptionality ruling or the record on appeal which would permit us to appropriately review whether the court abused its discretion in concluding that the case was not exceptional.” Thus, the Federal Circuit felt “constrained to vacate the district court’s determination” and remand.
Ollnova Technologies Ltd. v. ecobee Technologies ULC
Nos. 2025-1045, -1046 (Fed. Cir. (E.D. Tex.) June 4, 2026). Opinion by Chen, joined by Cunningham and Stark.
Ollnova sued ecobee for infringement of four patents (the ’495, ’371, ’887, and ’282 patents) directed to improvements in wireless communications used in building automation systems. At trial, a jury (i) found that ecobee infringed at least one of the patents, but without identifying which patent or patents; (ii) found that the asserted claims of the ’495 patent were not directed only to “well-understood, routine, and conventional” technology; (iii) found that the asserted claims of the ’282 patent were invalid; and (iv) awarded Ollnova damages. The district court denied each of ecobee’s post-trial motions.
On appeal, the Federal Circuit addressed several issues relating to infringement and eligibility.
First, ecobee argued that the verdict form improperly combined all asserted patents into a single infringement question and permitted the jury to find liability without unanimous agreement that ecobee infringed any particular claim of any patent. The Federal Circuit agreed. The court relied on recent precedent in ruling that, “to ensure a unanimous verdict, the verdict form needed to have included, at the very least, separate infringement questions for each asserted patent.” The district court thus abused its discretion by submitting a single infringement question to the jury covering all the asserted patents. The Federal Circuit therefore vacated the infringement judgment.
Next, the Federal Circuit agreed with ecobee that the jury instructions and verdict form on the ’495 patent’s eligibility were erroneous. The district court held at Alice step one that the claims were directed to an abstract idea, and that there were “factual disputes” concerning Alice step two. However, as the Federal Circuit explained, “neither the district court’s Alice step two verdict form nor the related jury instructions informed the jury that the ’495 patent’s claims were directed to an abstract idea, much less specified what that abstract idea was. Nor did they instruct the jury that the abstract idea itself could not supply the inventive concept under Alice step two.” The Federal Circuit thus vacated and remanded for further proceedings on Alice step two.
The Federal Circuit then turned to ecobee’s request for judgment as a matter of law (JMOL) that the ’495 patent’s asserted claims are not patent eligible. After reviewing the record, the Federal Circuit concluded that “the record contains sufficient evidence from which a reasonable jury could have found that the claimed dual-network architecture of the ’495 patent was not well-understood, routine, or conventional,” meaning JMOL was unwarranted.
Next, the Federal Circuit addressed ecobee’s contention that the district court erroneously concluded that the ’887 patent’s asserted claims are not directed to an abstract idea. The Federal Circuit disagreed with ecobee, ruling that “the claims here are directed to a specific technology-based improvement in the operation of a network, here using a ‘wireless automation device.’” The claims did not “merely describe collecting and communicating data in the abstract.” Instead, they recite “a particular technique governing when and how information is transmitted within a network using a wireless automation device.”
The Federal Circuit reached a similar conclusion for the asserted claims of the ’371 patent.
Finally, the Federal Circuit rejected ecobee’s request for JMOL that the asserted claims of the ’371 patent are not infringed. The court ruled that “substantial evidence supports the jury’s finding of infringement even under ecobee’s interpretation of the claims.”
In the end, the Federal Circuit vacated both the infringement and damages judgments and remanded for a new trial on those issues. The court also vacated and remanded for further proceedings under Alice step two as to the ’495 patent. And the court affirmed the district court’s determination that the asserted claims of the ’887 and ’371 patents are not directed to an abstract idea, and affirmed the denial of ecobee’s motion for JMOL of noninfringement of the ’371 patent.
Hafeman v. Google LLC, et al.
Nos. 2024-1600, -1601, -1602, -1603, -1604, -1605 (Fed. Cir. (PTAB) June 5, 2026). Opinion by Hughes, joined by Dyk and Stoll.
Carolyn Hafeman owns several patents that generally relate to methods for displaying recovery and return information on a lost or stolen computer’s screen during or after boot-up. She sued LG Electronics alleging that certain LG products were sold pre-loaded with Google or Microsoft “Find My Device” features that infringe her patents.
In response, Google and Microsoft filed six IPR petitions challenging the patents and naming LG as a real party in interest. LG then served a Sotera stipulation representing that it would not pursue in the district court any ground raised or that reasonably could have been raised in the IPRs. The Board then instituted review and, in the end, issued three final written decisions finding all challenged claims unpatentable over the combination of the “Jenne” and “Cohen” prior art references.
Ms. Hafeman appealed, presenting three arguments: (1) that LG violated the Sotera stipulation, and the Patent Trial and Appeal Board abused its discretion by failing to address that violation in the final written decisions; (2) that the Board erroneously construed a claim term requiring “initiating or changing return information which appears on the display through remote communication without assistance by a user with the computer” (the “without assistance” limitation); and (3) that the Board improperly disregarded secondary considerations of nonobviousness.
The Federal Circuit addressed all three arguments. First, the court considered Ms. Hafeman’s contention that the Board acted arbitrarily by not addressing her argument that the IPR proceedings should be terminated given the district court’s finding that LG violated the Sotera stipulation. The Federal Circuit held, however, that this challenge was barred from judicial review under 35 U.S.C. § 314(d).
Although Ms. Hafeman characterized her argument as challenging the sufficiency of the Board’s final written decisions rather than the institution decision itself, the Federal Circuit disagreed and thus dismissed this portion of her appeal. The court explained: “The problem with Ms. Hafeman’s challenge is that it seeks to terminate the IPRs for reasons related to the institution decision because the Sotera stipulation was a consideration for institution. This makes clear that her challenge has institution as its direct, immediate, express subject and is thus beyond our review.”
Next, the Federal Circuit affirmed the Board’s construction of the “without assistance” limitation and the Board’s associated findings of unpatentability. The court rejected Ms. Hafeman’s proposed construction arguments, ruling that it “conflicts with the claim’s plain language” and “also conflicts with the language in the specification.” The Federal Circuit also ruled that her arguments on the prosecution history were unpersuasive.
Lastly, the Federal Circuit rejected Ms. Hafeman’s arguments regarding secondary considerations of nonobviousness. The court ruled that the Board’s analysis was thorough and supported by substantial evidence, including its handling of a nexus between her commercial embodiment of the invention and the patent claims. And the court ruled that her arguments regarding evidence of copying were forfeited.