Recent case law on 35 U.S.C. § 101 :
Recent case law on 35 U.S.C. § 101 : The Federal Circuit, in the decision of Mortgage Grader, Inc v. First Choice Loan Services dated January 20, 2016, affirmed the district court's finding that the claims are directed to patent-ineligible subject matter. The claims-in-suit recite systems and methods of financial transactions including a method for a borrower to evaluate and obtain financing. The Federal Circuit applied the two-step Mayo test as clarified by Alice. In the first step, the court held that the claims, analyzed individually and as a whole, recite nothing more than the abstract idea of "anonymous loan shopping." In the second step, the court reasoned that the claims add only generic computer components that do not satisfy the inventive concept requirement, and that the claims did not solve a problem unique to the Internet and were not adequately tied to a particular machine or apparatus.