AGI SureTrack v. Farmers Edge: A Sensor and GPS Patent That Failed §101

AGI SureTrack LLC v. Farmers Edge Inc.; Farmers Edge (US) Inc., Fed. Cir. Nos. 2024-1730, 2024-1830 (June 2, 2026), is a precedential opinion authored by Circuit Judge Mayer, joined by Chief Judge Moore and Circuit Judge Lourie, with no dissent or concurrence. The court affirmed the District of Nebraska's grant of summary judgment that five AGI SureTrack patents covering farm equipment data collection are directed to patent-ineligible subject matter under 35 U.S.C. § 101. The court also vacated the district court's no-exceptionality determination under 35 U.S.C. § 285 and remanded for further fee-shifting consideration. The case below was AGI SureTrack LLC v. Farmers Edge Inc., No. 8:22-cv-00275-JFB-SMB (D. Neb.), Senior Judge Joseph F. Bataillon presiding.

The patents in suit were marketed as solving a real-world interoperability problem: farm equipment from different manufacturers stores and encodes operational data in incompatible formats, and that data is hard to consolidate into a useful farm-level record. The claimed inventions used passive sensors, GPS receivers, stored implement profiles, and a relay device to capture operating events and travel paths and assemble them into an electronic farm record.

That fact pattern is closer to sensors and IoT than to pure data aggregation. The Federal Circuit's holding nevertheless treated it as an abstract idea unable to clear Alice step two on generic hardware. That makes the decision broader, not narrower, in its implications for the next generation of agtech, telematics, and IoT patents.

This article presents the Federal Circuit's June 2, 2026 opinion and published law-firm and trade-press analysis for educational purposes. It is not legal advice. Consult a registered patent attorney for filing or litigation decisions.

The five patents at issue

The asserted patents and a one-line description of each:

The court did not separately analyze each patent. It treated claim 1 of the '937 patent as representative because AGI made no separate eligibility arguments for the other asserted claims, and the five patents share nearly identical specifications. The per-patent descriptions above are based on each patent's stated scope, not on the court's per-patent analysis. Patent numbers and characterizations drawn from the Federal Circuit opinion and published IPWatchdog and Bloomberg Law coverage.

How the panel walked Alice

The opinion applies the Alice/Mayo two-step framework. The reasoning is worth tracking carefully because it is doing more work than a casual reading of "agricultural data is abstract" would suggest.

Step one: directed to an abstract idea

At step one, the panel concluded that the claims are "directed to the abstract idea of collecting, processing, and sharing data." That formulation is broad. It does not turn on the agricultural context. It does not turn on the use of GPS or sensors. It articulates a category of human activity (collect, process, share information) and locates the claims squarely inside it.

The panel cited the long line of Federal Circuit cases finding data-collection-and-processing claims abstract: Electric Power Group v. Alstom (collecting and analyzing power-grid data), Two-Way Media v. Comcast (real-time monitoring of streaming data), FairWarning IP v. Iatric Systems (analyzing audit log data for suspicious patterns). The agricultural setting did not differentiate AGI SureTrack's claims from this line.

Step two: no inventive concept

At step two, the panel found that the hardware named in the claims (microprocessor, bus connector, GPS receiver, memory, implement-profile storage) was "generic, off-the-shelf." The claims did not improve any of these components. They did not invent a new sensor, a new GPS architecture, or a new memory structure. They used standard components in standard ways to accomplish the abstract idea identified at step one.

The panel's treatment of "implement profiles" is the most instructive part of the step-two analysis and the part most worth carrying into future drafting. The profiles were stored records that the system used to interpret incoming sensor data: when a piece of equipment sent a bus message, the system matched it against the profile to recognize what event had occurred. The panel characterized this as data used to interpret other data. That characterization is the doctrinal hinge. Because the profiles did not change any computer's underlying function, did not improve the data path, and did not invent a new sensor architecture, they could not supply the inventive concept the claims lacked. The claims, in the panel's words, did not recite a specific improvement in computer functionality.

The panel then articulated the rule that has been doing increasing work in 2026 §101 jurisprudence: automating or accelerating an abstract idea does not supply an inventive concept. AGI SureTrack's argument was, in essence, "humans cannot do this at scale; the equipment does it automatically; therefore there is an inventive contribution beyond the abstract idea." The panel rejected that framing. Speed and scale, accomplished through generic components, do not transform an abstract idea into a patent-eligible application of that idea.

That is the doctrinal payload most worth carrying forward. It is not new law. It is a consolidation of a line of cases stretching back to OIP Technologies v. Amazon and reinforced in SAP America v. InvestPic and Yu v. Apple. AGI SureTrack adds a recent, precedential, sensor-rich data point to that line.

The §285 vacatur: a piece of the story that is easy to miss

Below, the District of Nebraska had granted summary judgment for Farmers Edge on §101 but denied Farmers Edge's motion for attorneys' fees under § 285, finding the case was not exceptional. The Federal Circuit vacated that no-exceptionality determination and remanded for reconsideration in light of allegations of inequitable conduct and litigation misconduct.

That is not a small footnote. It means Farmers Edge gets a second shot at attorneys' fees, and the district court must reassess exceptionality under Octane Fitness with a fuller record. Bloomberg Law's coverage led with the fee remand rather than the §101 affirmance, and the framing is worth absorbing: the holding for the patent owner here is not a clean §101 loss but a §101 loss with potential fee exposure attached.

Practitioners citing AGI SureTrack as a §101 precedent should note the §285 remand. The §101 holding is a clean affirmance. The litigation result for AGI is not clean, because the fee question is unresolved on remand.

What this signals for IoT, telematics, and agtech patents

The fact pattern in AGI SureTrack is not exotic. Sensors plus GPS plus a stored profile lookup plus a relay device that aggregates the captured data to a structured record describes a substantial portion of modern IoT, telematics, fleet-management, and connected-equipment systems. If those claims, drafted by experienced patent counsel and prosecuted to issuance, can fall at summary judgment under §101, that has portfolio-design implications.

Three takeaways that survive translation across domains:

1. "Sensors generate data" claims are vulnerable. Claims structured around "a sensor captures X, a processor receives X, a memory stores X, the system uses X to do Y" track the abstract-idea formulation almost word for word. The inventive concept has to live somewhere besides the data flow itself.
2. The improvement has to be technical, not informational. "Now you can make better farming decisions" is an informational improvement. "Our sensor consumes 40% less power than X" or "our profile matching avoids the collision problem in Y because of Z" is a technical improvement. The first kind does not save a claim at step two. The second kind has a fighting chance.
3. Generic hardware is the trap. A claim that recites "microprocessor," "memory," "GPS receiver," "communication interface" without describing what is non-generic about how they are integrated invites the step-two analysis AGI SureTrack lost. The patent record needs to show what is technically distinctive about the architecture, not just what the system does at a behavioral level.

How this fits the broader 2026 §101 picture

AGI SureTrack is the most recent precedential Federal Circuit §101 decision affirming ineligibility on a software-adjacent fact pattern as of June 4, 2026. It joins several other 2026 data points worth tracking together:

• Patently-O's May 2026 corrected analysis of 16 years of §101 examiner data, showing the post-2019 rebound was steeper than initially reported and a modest decline under Stewart/Squires leadership. See our Software Patents After Alice page for the underlying numbers.
• BitHarmony v. Amazon (E.D. Va., May 26, 2026), where the court split §101 outcomes on video streaming patents, finding some claims survived as non-abstract. Useful as a counterpoint: well-drafted technical claims still clear §101.
• Pictometry International (Fed. Cir. May 23, 2026), affirming PTAB obviousness invalidations on aerial roof-measuring patents. Not §101 but a parallel trend: data-from-sensor patents are facing scrutiny across multiple invalidity doctrines.
• The April 30, 2026 USPTO SMED memo, encouraging Subject Matter Eligibility Declarations for AI, software, data analytics, and medical diagnostics. The office is providing tooling for applicants to build §101 evidence at the front end. See our Section 101 Declaration Strategy guide for how that works.

Read together: the front-end story (USPTO encouraging SMEDs to head off rejections) and the back-end story (Federal Circuit holding the line on data-collection claims through Alice step two) point in the same direction. Quality §101 records have to be built at filing. Claims drafted around generic hardware accomplishing an abstract data-handling function will struggle, regardless of how the technology is marketed.

What this case is not

This decision has been read in some early coverage as a broad signal that sensor and IoT patents are categorically abstract. That reading is wrong, and practitioners citing AGI SureTrack should be precise:

• This is not a ruling that sensors or IoT cannot be patented. It is a ruling that these five claims, as drafted, were ineligible despite sensors, GPS, message-bus data sources, and implement profiles, because the claimed improvement was data interpretation and recording using generic computer components. Claims that recite genuine technical improvements in the sensor architecture, the data path, the message protocol, or the system integration can survive Alice. The doctrinal vulnerability in AGI SureTrack was that the claimed novelty lived in which data was matched against which other data, not in any improvement to the underlying machinery.
• This is not a ruling that agricultural technology is categorically abstract. The agricultural context did not drive the result. The result was driven by the structure of the claims and the genericness of the recited components.
• This is not "data aggregation is abstract." The panel's articulation ("collecting, processing, and sharing data") is broad, but the holding is about specific claims that used generic components to interpret data with stored profiles. A claim that recites a specific, non-generic technical improvement in how the data is captured, transmitted, or processed is materially distinguishable.
• This is not new law. It is consolidation of a line of cases stretching back nearly a decade. What it adds is recency, precedential weight, and a sensor-rich fact pattern that previous cases did not have.
• This is not the end of Farmers Edge's exposure. The §285 remand could result in a fee award against AGI SureTrack. Practitioners citing this case should note that the fee story is unresolved.

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