University of Florida v. General Electric On February 26, 2019, the Federal Circuit ruled that the University of Florida (UFRF) waived its sovereign immunity by filing a patent infringement suit against GE, and could not avoid GE’s §101 defense. UFRF claimed that as an arm of the State of Florida, it enjoyed sovereign immunity, such that the district court lacked subject matter jurisdiction to hear GE’s §101 challenge to UFRF’s patent. The Federal Circuit disagreed. The court found that by bringing its infringement suit, UFRF waived its right to sovereign immunity. The court found UFRF’s patent invalid as patent ineligible, being directed to an abstract idea. UFRF claimed a method of integrating physiologic treatment data that required converting treatment data from a machine specific format to a machine independent format. The court found that the claim recited functional steps that could be applied to a general purpose computer, and that mere function of converting is not a specific improvement to the way computers operate.