IP Law Daily, PATENT—Fed. Cir.: Federal Circuit affirms patent ineligibility in ag data case, vacates fee ruling, (Jun 2, 2026)

By Patricia K. Ruiz, J.D.

The court found the patent claims were directed to abstract data processing and remanded the case for reconsideration of exceptionality.

The U.S. Court of Appeals for the Federal Circuit held that AGI SureTrack LLC’s asserted patents are directed to patent-ineligible subject matter because they claim the abstract idea of collecting, analyzing, and sharing farming data using generic computer components. Applying the Supreme Court’s Alice test, the court concluded the claims are abstract at step one and lack any inventive concept at step two. The court also vacated the district court’s determination that the case was not exceptional, finding the record insufficient to permit appellate review, and remanded for further proceedings on attorney’s fees (AGI Suretrack LLC v. Farmers Edge Inc., No. 24-1730 (Fed. Cir. Jun. 2, 2026)).

Background. The patents at issue describe systems for collecting, processing, and sharing farming operation data using devices connected to farm equipment, GPS signals, and centralized data storage. The representative claim recited a “relay device” with a microprocessor, memory, GPS receiver, and software instructions for extracting and interpreting machine data to record farming operations.

Patent eligibility. At Alice step one, the court agreed with the district court that the claims are directed to an abstract idea. It characterized the claimed invention as a computer-implemented method for “gathering and processing farming data,” emphasizing that the specification itself framed the invention in those terms. The court reiterated that claims involving generalized steps of collecting, analyzing, and presenting information using conventional computer components fall within the category of abstract ideas.

The court rejected AGI’s argument that the claims addressed a specific interoperability problem among different brands of farm equipment. It found no language in the claims explicitly directed to solving such a problem, and explained that even if interoperability were implicated, limiting the claims to a particular technological environment does not remove them from abstraction.

The court also dismissed reliance on “implement profiles”—data defining communication protocols—as insufficient to confer eligibility. It concluded that using one set of data to interpret another is itself an abstract concept, amounting to layering one abstract idea on another. Further, the court determined the claims do not improve the functioning of a computer or network but instead use generic components as tools to perform data-related tasks.

Inventive concept. At Alice step two, the court found no inventive concept. The claims relied on conventional hardware elements—such as a microprocessor, GPS receiver, and storage—operating in their ordinary capacities. The court held that automation and increased processing speed do not transform an abstract idea into a patent-eligible application.

Viewing the elements individually and as an ordered combination, the court concluded they merely implement the abstract idea of collecting and interpreting farming data without any technological innovation sufficient to satisfy § 101.

Exceptionality and attorney’s fees. On cross-appeal, the court addressed the district court’s determination that the case was not exceptional under § 285. The court explained that, while detailed reasoning is not required in every case, a district court generally must provide enough explanation to permit meaningful appellate review.

Here, the district court entered a “terse” ruling without articulating its reasoning, and the record did not otherwise support review of the decision. As a result, the court vacated the no-exceptionality determination and remanded for reconsideration, instructing that both parties be given an opportunity to present argument and evidence.

The court also addressed a procedural dispute regarding Federal Rule of Civil Procedure 54(d)(2)(B). It concluded that because the case was being remanded and a new judgment would be entered, a new fourteen-day period for filing a motion for attorney’s fees would be triggered upon entry of that judgment.

The Case is No. 24-1730.

Judge: Mayer, H.

Attorneys: Joan K. Archer (Cartlon, Fields Law Firm) for AGI Suretrack LLC. Nathan S. Mammen (Reichman, Jorgensen Law Firm) for Farmers Edge Inc.

Companies: AGI Suretrack LLC; Farmers Edge Inc.

Cases: Patent FedCirNews