The Federal Circuit’s decision in AGI SureTrack LLC v. Farmers Edge Inc. , Case No. (Fed. Cir. Jun. 2, 2026), provides another significant reminder that patents directed to collecting, analyzing, and transmitting information remain vulnerable under 35 U.S.C. § 101, even when framed as solving industry-specific technical problems. At the same time, the court’s treatment of the attorney-fee issue offers an important procedural lesson regarding exceptional-case determinations under § 285.
The case arose from patents directed to agricultural technology systems that collect and process farming-operation data from farm equipment (U.S. Patent Nos. 11,126,937, 10,963,825, 11,164,116, 11,361,261, and 11,507,899). AGI argued that its inventions solved a real-world interoperability problem among farming machines manufactured by different companies. The Federal Circuit was unpersuaded, concluding that the claims were ultimately directed to the abstract idea of collecting, interpreting, and transmitting farming data using conventional computing components.
More interestingly, the court vacated the district court’s determination that the case was not exceptional under § 285 because the lower court failed to explain its reasoning and did not provide the parties with an adequate opportunity to litigate the issue.
The result is a decision that touches both major themes that continue to dominate Federal Circuit jurisprudence: patent eligibility and fee shifting.
The Claimed Technology
The asserted patents concerned systems for tracking farming operations through data collected from agricultural equipment. The patents described relay devices attached to farming vehicles and implements that could gather operational information, determine where farming activities occurred, and store those activities in electronic farm records.
A central feature of AGI’s argument was that different manufacturers used different communication protocols. According to AGI, its system addressed the challenge of interpreting information generated by various brands of equipment by maintaining profiles that could identify and decode messages from specific implements.
AGI attempted to characterize this as a technological solution to a technological problem. That framing became the central issue in the eligibility dispute.
Alice Step One: Collecting and Processing Data Remains an Abstract Idea
The Federal Circuit began its analysis under the familiar two-step framework established by Alice Corp. v. CLS Bank.
At step one, the court focused heavily on the patents’ own specification. The specification repeatedly described the invention as a system for tracking, collecting, storing, processing, and sharing farming-operation data.
That characterization proved fatal.
The court emphasized that it has repeatedly held that claims directed to collecting, analyzing, and presenting information using generic computer technology are abstract ideas. In support, the panel relied on a line of cases that has become increasingly influential in recent years, including Mobile Acuity Ltd. v. Blippar Ltd., Electric Power Group v. Alstom, and Sanderling Management Ltd. v. Snap Inc.
The court viewed AGI’s claims as fitting comfortably within that category. Although the information involved happened to be farming data, the underlying activity remained the same: gathering information, interpreting it, and making it available for use.
Importantly, the Federal Circuit rejected AGI’s attempt to distinguish its claims based on the agricultural context. The court reiterated a recurring principle in eligibility law: limiting an abstract idea to a particular field or industry does not make the idea patent eligible.
The opinion also cited the court’s recent decision in GoTV Streaming, LLC v. Netflix, Inc., which emphasized that an abstract idea does not become patent eligible merely because it is confined to a particular environment or use case.
That aspect of the decision reflects a broader trend. Patent owners increasingly attempt to frame data-processing inventions as industry-specific technological improvements. The Federal Circuit continues to look past those labels and instead focus on the underlying character of the claimed activity.
The Interoperability Argument Falls Short
Perhaps the most notable portion of the opinion is the court’s treatment of AGI’s interoperability theory.
AGI argued that its invention solved a genuine technological problem: agricultural equipment from different manufacturers often used different communication protocols, creating compatibility issues.
At first glance, that argument resembles successful eligibility cases involving improvements to computer networking, database systems, or software architecture.
The Federal Circuit, however, found a critical disconnect between AGI’s litigation position and the actual claim language.
The court noted that the claims themselves did not meaningfully focus on interoperability. Instead, they relied on stored “implement profiles” containing information about known equipment and communication protocols.
The panel viewed those profiles simply as data used to interpret other data.
That distinction was important. Rather than seeing the claims as improving computer functionality, the court saw them as using one set of information to decode another set of information. The opinion relied in part on RecogniCorp LLC v. Nintendo Co. and ChargePoint, Inc. v. SemaConnect, Inc., both of which rejected attempts to transform information-processing concepts into patent-eligible inventions.
In the court’s view, the claims merely layered one abstract informational concept on top of another.
Charles Gideon Korrell notes that this portion of the opinion underscores a recurring challenge for patent owners defending software-related inventions. It is often not enough to identify a real-world technical problem. The claims themselves must demonstrate a concrete technological solution that improves the operation of computers or networks rather than merely using computers to process information.
No Improvement to Computer Functionality
The Federal Circuit also relied heavily on another familiar eligibility principle: a patent that improves a business process is not necessarily improving computer technology.
The court cited Customedia Technologies, LLC v. Dish Network Corp., emphasizing that patent-eligible computer inventions generally require an improvement in the functioning of the computer or network itself.
Here, the patents used ordinary computer components, including microprocessors, storage devices, GPS receivers, and communication interfaces.
Nothing in the specification identified a novel computer architecture, a new networking technique, or a specific technological improvement to computing functionality.
Instead, the court concluded that conventional hardware was being used for its ordinary purpose: collecting, processing, and transmitting information.
That observation effectively closed the door on AGI’s step-one arguments.
Alice Step Two: Generic Components Cannot Supply the Inventive Concept
The court’s step-two analysis was comparatively straightforward.
Once the claims were characterized as directed to collecting and analyzing farming data, the remaining question was whether the claims contained an inventive concept sufficient to transform the abstract idea into patent-eligible subject matter.
The answer was no.
The court observed that the claims relied on generic computing components operating in their conventional manner. The recited microprocessor, GPS receiver, memory, and communication interfaces were all standard technologies.
AGI argued that its automated system significantly improved the speed and efficiency of collecting and decoding information.
The Federal Circuit rejected that position as well.
Relying on decisions such as Trinity Info Media v. Covalent and OIP Technologies v. Amazon.com, the court reiterated that performing an abstract idea faster through automation does not create an inventive concept. Increased speed and efficiency, standing alone, are not enough.
Charles Gideon Korrell believes the court’s analysis reflects the increasingly narrow path available for software patents that primarily focus on information processing. Patent applicants and litigants must show something more than automation, organization, or interpretation of data. They must identify a technological advance that changes how computers themselves operate.
The More Interesting Issue: Attorney Fees Under § 285
Although the eligibility holding is important, the procedural discussion concerning attorney fees may ultimately attract equal attention.
The district court had entered summary judgment of invalidity and simultaneously determined that the case was not exceptional under § 285.
Farmers Edge challenged that ruling.
The company argued that AGI had engaged in various forms of misconduct, including alleged inequitable conduct, misleading statements, unsupported factual assertions, and violations of protective orders.
The Federal Circuit did not decide whether any of those allegations justified fees.
Instead, it focused on the process.
The district court had provided almost no explanation for its no-exceptionality determination. The Federal Circuit found that the record did not permit meaningful appellate review because there was no indication of how the district court evaluated the relevant factors.
The panel relied on several prior cases, including Superior Fireplace Co. v. Majestic Products Co., Energy Heating, LLC v. Heat On-The-Fly, LLC, and Innovation Technologies, Inc. v. Splash! Medical Devices, LLC.
Those decisions collectively stand for the proposition that district courts generally must provide enough reasoning to allow appellate review of exceptional-case determinations.
Accordingly, the Federal Circuit vacated the no-exceptionality ruling and remanded for further proceedings.
An Important Procedural Point on Rule 54
The opinion also contains a useful discussion of Federal Rule of Civil Procedure 54.
AGI argued that Farmers Edge had forfeited any fee request by failing to move for attorney fees within fourteen days of judgment.
The Federal Circuit disagreed.
Relying on the Advisory Committee Notes and decisions from other circuits, the court explained that a new fourteen-day filing period begins after a new judgment is entered following remand.
Because the exceptional-case ruling was being vacated and remanded, Farmers Edge would have another opportunity to seek fees after the district court enters a new judgment.
Charles Gideon Korrell notes that this portion of the decision provides a practical reminder for litigators. Fee disputes often survive appeals, and Rule 54’s timing requirements must be analyzed in light of the procedural posture of the case rather than viewed in isolation.
Key Takeaways
The decision reinforces several themes that have become increasingly prominent in Federal Circuit jurisprudence.
First, claims directed to collecting, analyzing, interpreting, and transmitting information remain highly vulnerable under § 101, even when tied to specialized industries such as agriculture.
Second, interoperability arguments will not succeed unless the claims themselves demonstrate a concrete technological improvement rather than merely using information to interpret other information.
Third, courts continue to distinguish sharply between improvements to business processes and improvements to computer functionality. The former generally face substantial eligibility challenges.
Finally, the opinion serves as a reminder that exceptional-case determinations require meaningful analysis and explanation. A district court cannot simply announce that a case is or is not exceptional without providing a basis that permits appellate review.
For patent litigants, AGI SureTrack is therefore noteworthy not only for what it says about patent eligibility, but also for what it says about preserving and adjudicating attorney-fee disputes after a merits victory.
Leave a Reply