documents, recognizing certain information within the collected data, and storing that information in memory were ineligible. This was true despite noting that, if the claims were construed in the most favorable manner to the appellants, the claims would require scanning and processing technology. The Versata court also summarized two pre-Alice decisions in which the rulings were consistent with Alice: In Bancorp Services, L.L.C. v. Sun Life Assurance Co., [the Federal Circuit] found ineligible claims directed to the abstract idea of managing a stable value life insurance policy. In CyberSource Corp. v. Retail Decisions, Inc., [the Federal Circuit] found that a broadly worded method claim and a claim reciting a computer readable medium for executing the method claim were ineligible. [The Federal Circuit] concluded the claims were drawn to a method of verifying the validity of credit card transactions over the Internet, and the steps in the method could be performed in the human mind or by a human using a pen and paper. In the 2015 Versata case, itself, the Federal Circuit affirmed the final order of the Patent Trial and Appeal Board (PTAB), the recently created adjudicatory arm of the United States Patent and Trademark Office (USPTO), invalidating as patent ineligible the claims in issue of Versata's patent on a method of determining what price to charge a customer. It said, "Using organizational and product group hierarchies to determine a price is an abstract idea that has no particular concrete or tangible form or application." Moreover, the implementation was a "purely conventional" use of a computer. Loyalty Conversion and other 2014 district court cases The software cases after Alice adopt its method of legal analysis, based on the decision of the Supreme Court in the Mayo case. This calls for a two-step analysis. First, the court determines whether the claimed invention is based on an abstract idea or principle of some sort, often expressed at a high level of generality, such as a computerized escrow or surety arrangement, as in the Bilski and Alice cases. If the claimed invention is directed to an abstract idea, the court proceeds to the second step of analysis, which is to determine whether the patent adds "something extra" to the idea that embodies an "inventive concept." If there is no addition of an inventive element to the underlying abstract idea, the court will find the patent invalid under section 101. Few software patents