Section 101 of the Patent Act generally extends patent protection to “any new useful process, machine, manufacture, or composition of matter.” Natural laws and phenomena and abstract ideas are not eligible for patent protection. Prior to Ultramercial, Inc. v. Hulu, LLC, No. 2015-1544 (Nov. 14, 2014), the Federal Circuit had twice held that a method for providing free online content in exchange for viewing advertising was eligible for patent protection. However, in last year’s Alice Corp. v. CLS Bank Int’l ruling, the Supreme Court established a two-part test for determining patent eligibility under Section 101. First, a court determines whether an invention is directed to a natural law, natural phenomena, or abstract concept. If so, the invention is ineligible for patent protection unless its additional features render the invention “significantly more” than the law or idea itself. The Federal Circuit found that the invention at issue failed Alice’s test, and thus affirmed dismissal of the infringement suit. The invention concerned the abstract idea of showing an advertisement in exchange for delivering free content, and its additional aspects were routine and conventional, amounting to simple application of the idea to the Internet. While the court stated that not all software inventions are necessarily directed to an abstract idea, the ruling indicates that the Supreme Court’s recent Section 101 rulings, such as Alice Corp., have restricted the patent eligible realm.