The Federal Circuit has reversed a $533M infringement verdict against Apple after ruling that claims from three data access and storage patents (7,334,720; 8,118,221; 8,336,772) asserted by Smartflash LLC and Smartflash Technologies Limited (collectively, “Smartflash”) are invalid under Alice (2016-1059). In an opinion issued on March 1, the Federal Circuit ruled that while District Judge Rodney Gilstrap had correctly found the patents are directed to an abstract idea—“conditioning and controlling access to data based on payment”—he had erred in finding that the claims contained the requisite inventive concept. Rather, the court held, the claims merely implemented that abstract idea using generic Internet activity and computer hardware, and are thus not patent-eligible.