The Federal Circuit gave patent prosecutors a useful Section 101 prosecution decision in In re McFadden.
The Board had treated apparatus and system claims as ineligible because they lacked sufficient structure. The Federal Circuit held that the analysis could not stop at that categorical premise and required a more careful statutory-category inquiry.
The decision does not mean every broad apparatus claim survives eligibility review. It does mean the PTO must separate the threshold statutory-category question from later abstract-idea and definiteness concerns.
For applicants drafting computer-implemented inventions, the case is a reminder to give examiners structural anchors while also preserving arguments against overbroad eligibility shortcuts.