Data Engine Techs. LLC v. Google LLC  On October 9, 2018, the Federal Circuit found under §101 that DET’s claim for a method of navigating three-dimensional electronic spreadsheets is not directed to an abstract idea. The claim recites a “specific and particular manner of navigating a three-dimensional spreadsheet that improves the efficient functioning of computers.”  At the same time, DET’s claim for a method of organizing three-dimensional spreadsheets was found to be patent ineligible and directed to an “abstract idea of identifying and storing electronic spreadsheet pages” for not being limited to a specific technical solution and improvement in electronic spreadsheet functionality.  In determining eligibility under §101, the court stated that “the question of abstraction is whether the claim is directed to the abstract idea itself” in that the court “must consider the claim as a whole to determine whether the claim is directed to an abstract idea or something more.”