The Federal Circuit on June 2, 2026 affirmed that a set of agricultural-data patents asserted by AGI SureTrack LLC against Farmers Edge Inc. claims patent-ineligible subject matter under 35 U.S.C. § 101, but it vacated and remanded a separate ruling that the case was not exceptional for purposes of attorney’s fees. The decision splits the result: the patents fall, but the question of whether the losing side must pay fees is sent back for the district court to explain itself.

AGI had asserted five patents sharing nearly identical specifications, directed to capturing, processing, and sharing farming-operation data using devices attached to farm equipment. The panel treated claim 1 of U.S. Patent No. 11,126,937 as representative; AGI made no separate eligibility arguments for the other claims. That claim recites a "relay device" with a microprocessor, a bus connector to a farm vehicle’s message bus, a GPS receiver, and a memory storing "implement profiles," running an application that extracts message content, matches the equipment to a stored profile, and records the farming operation in an electronic farm record.

Alice step one: a familiar abstract idea

Applying the two-step Alice framework, the panel held at step one that the claims are directed to an abstract idea. AGI argued its claims were eligible because they offered a "specific and novel" way to collect and interpret data from different brands of farm equipment that use incompatible encoding rules. The court was not persuaded, noting first that the claim language itself does not refer to any "interoperability" problem. Even accepting AGI’s characterization, the panel held, the claims describe a computer-implemented method for gathering and processing farming data — the kind of "collecting, analyzing, and presenting information" that, when done with conventional generic computer components, the court has repeatedly found abstract.

The panel rejected the argument that limiting the claims to farming data, or to a system using stored "implement profiles" to decode equipment messages, changed the analysis. It characterized the implement profiles as simply a collection of data used to interpret other data, and described the claimed method as one that "merely adds one abstract concept to another."

an abstract idea remains an abstract idea even when narrowed—e.g., by subject matter—to a particular use or environment.AGI SureTrack LLC v. Farmers Edge Inc., No. 2024-1730 (Fed. Cir. June 2, 2026)

The court also addressed AGI’s contention that the claims improve computer functionality. It held they do not, finding instead that they invoke generic components to collect, analyze, and transmit data, and that AGI’s specification is "silent as to any specific structural or inventive improvements in computer functionality." On that basis the panel agreed with the district court that the claims are directed to an abstract idea at step one.

Alice step two: automation is not an inventive concept

At step two, the panel searched for an inventive concept and found none. The claims rely on a microprocessor, bus connector, GPS receiver, and memory storage area used in a conventional manner. The court acknowledged that AGI’s system uses automation to speed up collecting and decoding equipment data, but held that improved speed from applying an abstract idea on a computer does not supply an inventive concept. Whether viewed individually or as an ordered combination, the panel concluded, the claim elements do not transform the abstract idea of collecting, interpreting, and transmitting farming data into a patent-eligible application. The court therefore affirmed the summary judgment of ineligibility for all of the asserted patents.

The exceptional-case cross-appeal

Farmers Edge prevailed on eligibility but cross-appealed the district court’s ruling that the case was not exceptional under 35 U.S.C. § 285, which allows fee awards in exceptional cases. Farmers Edge had argued the case stood out for reasons including alleged inequitable conduct during prosecution, misleading statements about abandoned claims, and improper litigation tactics. It also contended the district court entered the no-exceptionality judgment sua sponte, without giving it an opportunity to present argument or evidence.

The Federal Circuit agreed that the record did not permit meaningful review. While the court noted it has not always required a district court to detail its reasoning for denying fees, it explained that under most circumstances a court should provide some indication of its reasoning to allow appellate review. Here, the panel found nothing in the "terse no exceptionality ruling" or the record that would let it assess whether the district court abused its discretion. It vacated that determination and remanded with instructions that the district court reassess exceptionality — after giving both parties an adequate opportunity to present argument — and, if the case is exceptional, whether a fee award is appropriate.

A timing point on the fee motion

The court also resolved a forfeiture argument. AGI contended Farmers Edge forfeited fees by not moving within fourteen days of judgment under Federal Rule of Civil Procedure 54(d)(2)(B). The panel pointed to the Rule’s Advisory Committee Note explaining that a new filing period begins automatically when a new judgment is entered after an appellate remand. Because the panel was vacating and remanding the no-exceptionality determination, a new fourteen-day period will be triggered once the district court enters judgment on remand.

What the court decided

The panel — Chief Judge Moore and Judges Mayer and Lourie, with Judge Mayer writing — affirmed-in-part, vacated-in-part, and remanded. The asserted patents, including U.S. Patent No. 11,126,937, are held directed to ineligible subject matter; the district court’s no-exceptionality ruling is vacated for lack of explanation and a fresh hearing on whether the case warrants fees. Costs were assessed to Farmers Edge. The eligibility portion of the ruling turns on settled Alice doctrine: narrowing an abstract idea to a particular field, and applying it with generic computers and automation, does not by itself make a claim patent-eligible.