AGI SureTrack LLC v. Farmers Edge Inc.

AGI SureTrack LLC v. Farmers Edge Inc. The Federal Circuit affirmed that the asserted claims are patent ineligible because they are directed to collecting, interpreting, and transmitting farming-operation data using generic computer components, with no inventive concept. The court vacated and remanded the no-exceptionality ruling because the district court provided no reasoning sufficient for appellate review and did not give the parties an adequate opportunity to address § 285. The decision reinforces that narrowing data-processing claims to a specific industry and data type will not save them under Alice absent a claimed technological improvement, and that unexplained § 285 rulings remain vulnerable on appeal. Affirmed-in-part, vacated-in-part, and remanded; Farmers Edge awarded costs. The asserted patents concern automated capture, processing, and sharing of farming-operation data using a relay device with a microprocessor, bus connector, GPS receiver, memory, and stored implement profiles. At Alice step one, the court held the claims were directed to the abstract idea of collecting, analyzing, and presenting information, even though limited to farming data and alleged equipment-communication-protocol issues. At Alice step two, the claimed components and automation did not add an inventive concept because they used conventional computer hardware to perform routine data collection and analysis faster. The court rejected AGI's reliance on stored implement profiles, treating them as data used to interpret other data rather than a specific improvement to computer functionality. On § 285, the court vacated the district court's unexplained no-exceptionality determination and held that a new Rule 54 fee-motion period will run after entry of judgment on remand. § 101 attorney fees / sanctions remand waiver / forfeiture precedential § 101 attorney fees / sanctions remand waiver / forfeiture precedential § 101 attorney fees / sanctions remand waiver / forfeiture