patent ineligible as mere abstract ideas implemented in a conventional way without embodying any inventive concept. Digitech In Digitech Image Technologies, LLC v. Electronics for Imaging, Inc., the Federal Circuit invalidated a patent on a "device profile" and methods for generating "device profiles." The device profile was a collection of information about a graphic image, and it was generated by combining data sets containing such information. The court held that the device and method for generating it were abstract ideas and patent ineligible: "Without additional limitations, a process that employs mathematical algorithms to manipulate existing information to generate additional information is not patent eligible." buySAFE In buySAFE, Inc. v. Google, Inc., the Federal Circuit invalidated under section 101 a patent on a computerized surety system for online transactions. The court said the computer implementation of the underlying surety idea was "not even arguably inventive." The court concluded: "In short, with the approach to this kind of section 101 issue clarified by Alice, it is a straightforward matter to conclude that the claims in this case are invalid." The court remarked in passing, however, that if "enough extra is included in a claim, it passes muster under section 101 even if it amounts to a business method." But the court did not explain or illustrate what would be "enough extra." DDR Holdings In DDR Holdings v. Hotels.com, the Federal Circuit upheld one patent and invalidated several others under Alice. This is the only instance since the Alice decision in which the Federal Circuit held a patent to be eligible. The court said that the eligible patent solved an Internet-centric problem in an inventive way. (It essentially framed one website within another, so that it appeared to be a part of the other site.) Versata v. SAP In Versata Development Group, Inc. v. SAP America, Inc., the Federal Circuit summarized its holdings in several other post-Alice cases that are not summarized above. The following summaries are extracted from the Federal Circuit's opinion in the Versata case: In Ultramercial, [the Federal Circuit] found that claims directed to the abstract idea of using an advertisement as an exchange or currency were ineligible even though the claims were tied to a general purpose computer and invoked the Internet. In Content Extraction &Transmission LLC v. Wells Fargo Bank, National Ass'n, [the Federal Circuit] found that claims directed to the abstract idea of collecting data from hardcopy