Soil Sample Tracking Patent Not Invalid Under 35 U.S.C. § 101

The court denied defendant's motion for summary judgment on the ground that plaintiff’s soil sample tracking patent encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "The Court agrees with the Defendant that soil sampling for the purpose of evaluating the nutritional deficiencies in a field is an abstract idea. However, the Court does not agree that a method for performing soil sampling is necessarily abstract. . . . The [patent-in-suit] purports to solve issues associated with existing techniques by coming to the end result more efficiently and accurately. Therefore, the Court does not find that the [patent] is directed to an abstract idea that is ineligible for patent protection."

Agri-Labs Holdings LLC v. TapLogic, LLC, 1-15-cv-00026 (INND January 16, 2018, Order) (Springmann, USDJ)