IP Hot Topic: Cultivating a § 101 Strategy – Lessons from AGI SureTrack v. Farmers Edge

In AGI SureTrack LLC v. Farmers Edge Inc., No. 24-1730 (Fed. Cir. 2026), the Federal Circuit affirmed the district court’s grant of summary judgment holding that AGI’s claims relating to collecting, processing and sharing farming data were ineligible under § 101. Claim 1 of U.S. Patent No. 11,126,937 recites a relay device for tracking farming operations including a microprocessor, bus connector, GPS receiver, memory, and an application program. The application program includes instructions that cause the system to extract content from messages from farming equipment to determine a set of operating events and a travel path for a farming operation, and to record the farming operation and descriptive information in an electronic record.

At Alice step one, the court found the claims relate to an abstract idea and do not provide any structural or inventive improvements in computer functionality. AGI argued that its claims cover a specific and novel way to collect and interpret data from a variety of different brands of farm equipment, as manufacturers may employ incompatible rules for encoding and transmitting data. However, the court disagreed with AGI’s contention, noting that there is nothing in the claims referring to “interoperability” problems between different brands of farming equipment. The court held that “claims reciting generalized steps of collecting, analyzing and presenting information, using nothing other than the conventional operations of generic computer components, are directed to abstract ideas.” Mobile Acuity Ltd. v. Blippar Ltd., 110 F.4^th 1280, 1293 (Fed. Cir. 2024); Elec. Power Grp., LLC v. Alstom SA, 830 F.3d 1350, 1355 (Fed. Cir. 2016). Limiting the claims to a particular type of data, e.g., farming data, does not render the claims non-abstract. At Alice step two, the court found the claims recite only generic computer components that are used in a conventional manner to collect, analyze, and display data.

The court’s holding in AGI reaffirms several important lessons for patent applicants. Applicants should ensure the claims reflect the technological improvement described in the Specification. While the claims do not have to expressly recite the improvement in identical terms, the claims should capture the features that provide the technological improvement. In AGI, the patent owner argued the claims improved interoperability between farming equipment, but the claims lacked any limitations addressing that problem.

Applicants should also consider the end result of the claim. In claim 1 of the ‘937 patent, the final step was to simply record the farming operation and descriptive information in an electronic record. Thus, the farming data was not collected in service of determining an action to take, identifying an issue, or accomplishing a particular task. Applicants with inventions relating to data collection and processing should carefully consider to what end the data is being collected and analyzed. As the Federal Circuit has repeatedly affirmed, claims that result in merely storing or displaying the results of the data analysis, without more, are not likely patent eligible and have a higher risk of invalidation under §101. By contrast, claims are more likely to survive § 101 where the results are used to drive a specific technological action that alters the system’s operation or produces a non-conventional real-world effect.