In Electric Power Group, LLC v. Alstom S.A., Appeal No. 2015-1778, the Federal Circuit upheld the district court’s grant of summary judgment that the claims were not directed to patent-eligible subject matter under § 101.

The claims were directed to monitoring and analyzing data from disparate sources in the context of electric power grids. The Federal Circuit applied the Alice/Mayo test and found that the claims were directed to an abstract idea and did not go beyond stating the collection, analysis, and display of available information in general terms.