AGI SURETRACK LLC v. FARMERS EDGE INC.

Authored by: Jeremy J. Gustrowsky

The Federal Circuit recently addressed a dispute involving patents covering automated systems for collecting and sharing farming data, finding the claims patent ineligible while also sending the attorney’s fees question back to the district court for a more thorough analysis.

AGI SureTrack LLC sued Farmers Edge Inc. and Farmers Edge (US) Inc. for infringing five related patents, including U.S. Patent No. 11,126,937. The patents generally describe a relay device that attaches to farming equipment, captures operational data in real time using GPS and a connection to the equipment’s message bus, and then processes and shares that data through an online exchange. AGI argued its claims solved a real-world interoperability problem because different brands of farm equipment use different communication protocols, and its system stored “implement profiles” that allowed the relay device to decode messages from various manufacturers.

The court was not persuaded. Applying the familiar two-step Alice framework, the panel concluded that claim 1 of the ‘937 patent (treated as representative) was directed to the abstract idea of collecting, analyzing, and transmitting information. The court noted that nothing in the claim language actually referenced interoperability, and even assuming the claims did address that issue, narrowing an abstract idea to a particular field like farming does not rescue it from ineligibility. The “implement profiles” were just a collection of data used to interpret other data, which the court characterized as merely adding one abstract concept to another.

At step two, the court found no inventive concept that would transform the abstract idea into a patent-eligible application. The claimed device used generic components, including a microprocessor, bus connector, GPS receiver, and memory storage, all operating in conventional ways to collect and analyze data. While automation may speed up the process, the court reiterated its long-standing position that using a computer to perform routine tasks faster does not confer patent eligibility. The specification itself was silent on any specific structural or inventive improvements to computer functionality.

The cross-appeal produced a different outcome. Farmers Edge had argued the case was exceptional under 35 U.S.C. § 285, pointing to alleged inequitable conduct during prosecution, misleading statements about abandoned claims, improper litigation tactics, and alleged violations of protective orders. The district court, however, had ruled sua sponte that the case was not exceptional without explaining its reasoning and without giving Farmers Edge an opportunity to brief the issue. The Federal Circuit found this insufficient for meaningful appellate review and vacated that ruling, instructing the lower court to reassess the exceptionality question after allowing both parties to present their arguments.

The court also addressed a procedural wrinkle raised by AGI, which contended Farmers Edge had forfeited its fee request by failing to file a motion within fourteen days of the original judgment under Federal Rule of Civil Procedure 54(d)(2)(B). Relying on the Advisory Committee Notes and decisions from other circuits, the panel explained that a new fourteen-day window opens when a new judgment is entered following an appellate remand. Farmers Edge will therefore get a fresh opportunity to seek fees once the district court enters judgment on remand.

This decision reinforces how difficult it remains to obtain and defend software patents that recite data collection, processing, and sharing using generic hardware, even when the data relates to a specific industry like agriculture. It also serves as a useful reminder that district courts should explain their reasoning when deciding exceptional case motions, and that parties deserve a meaningful chance to be heard before such rulings issue.