In Integrated Technology Solutions, LLC v.
iRacing.com Motorsport Simulations, LLC, No.
1:21-cv-11477, Judge Talwani granted iRacing's motion to
dismiss, finding that ITS's patent directed to modifying
components of a video game racing track to alter user experience
was invalid under 35 U.S.C. § 101. The Court applied the
two-step framework laid out by the Supreme Court in Alice
Corp. Pty. Ltd. v. CLS Bank Int'l., 573 U.S. 208 (2014),
examining first whether the claims at issue are directed to laws of
nature, natural phenomena, or abstract ideas, and, second, whether
the elements of each claim both individually and as an ordered
combination transform the nature of the claim into a
patent-eligible application.