According to the asserted patents, the self-referential model allows for faster searching, more flexibility in configuring the database, and more effective storage of images and unstructured text. The district court determined that the asserted claims of these patents, however, were not patent eligible under because they were directed to the abstract concept of “organizing information using tabular formats.” On review, the Federal Circuit first laid the groundwork for its analysis with the principals that “plainly contemplates that the first step of the inquiry is a meaningful one, ., that a substantial class of claims are directed to a patent-ineligible concept,” and that claims are to be evaluated under Step One “based on whether ‘their character as a whole is directed to excluded subject matter.’” Both of these statements are encouraging for patentees but are simply recitations of existing law. The Federal Circuit next interpreted ’s Step One analysis in the context of computer-related technology to determine that it is “relevant to ask whether the claims are directed to an improvement to computer functionality versus being directed to an abstract idea, even at the first step of the analysis.” Underlying this conclusion is that the court “do[es] not read to broadly hold that all improvements in computer-related technology are inherently abstract” nor that “claims directed to software, as opposed to hardware, are inherently abstract and therefore only properly analyzed at the second step of the analysis.” The Federal Circuit’s reasoning in appears to create a new inquiry for computer-related technology under Step One: “whether the focus of the claims is on the specific asserted improvement in computer capabilities … or, instead, on a process that qualifies as an ‘abstract idea’ for which computers are invoked merely as a tool.” Turning to the self-referential database model at issue, the court held that the focus of the asserted claims is “on an improvement to computer functionality itself, not on economic or other tasks for which a computer is used in its ordinary capacity.” The court’s conclusion was bolstered by the disclosed benefits of the model—increased flexibility, faster search times, and smaller memory requirements. Finally, the court distinguished (patent eligible) claims directed to a specific improvement in computer functionality with (patent ineligible) claims that recite use of an abstract mathematical formula on any general purpose computer, recite a purely conventional computer implementation of a mathematical formula, or recite generalized steps to be performed on a computer using conventional computer activity. On its face, the opinion is a boon for patentees of software-related technologies because it appears to create a new safe zone for “improvements in computer functionality.” However, is this carve-out as clear and sound as it may seem? The first clue in answering that question may come from the opinion, issued just days after and from the same authoring Judge as . . The fate of , in the opinion, is quite different from that of the patents in : “the [’295 patent] claims no more than the abstract idea of classifying and storing digital images in an organized manner.” Accordingly, affirmed the district court’s determination that the patent fails to claim patent-eligible subject matter under § 101. The patent-in-suit in related to “an apparatus for recording of a digital image, communicating the digital image from the recording device to a storage device, and to administering the digital image in the storage device.” The claimed invention was intended to address challenges in organizing a large database of digital images stored on a computer. The goal of the inventors was to administrate and archive the “digital images simply, fast and in such way that the information therefore may be easily tracked” using manually or dynamically assigned “classification data.” Under Step One, the Federal Circuit first observed that “representative claim 17 is drawn to the concept of classifying an image and storing the image based on its classification,” but then unexpectedly appears to move into the Step Two analysis in the very next sentence, stating: “the specification makes clear that the recited physical components merely provide a generic environment in which to carry out the abstract idea of classifying and storing digital images in an organized manner.” Returning to Step One, the opinion next recites the carve-out of , but concludes that “the [TLI] claims here are not directed to a specific improvement to computer functionality.” The court reasoned that the claims of the asserted patent are instead “directed to the use of conventional or generic technology in a nascent but well-known environment.” Still within the context of its Step One analysis, the court further criticized the ’295 patent for “fail[ing] to provide any technical details for the tangible components” and “predominately describ[ing] the system and methods in purely functional terms” rather than “describ[ing] a new telephone, a new server, or a new physical combination of the two.” The opinion also highlights that the telephone and server components of the asserted claims are described in the specification as being well-known. The court concluded that “the focus of the patentee and of the claims was not on an improved telephone unit or an improved server.” For all these reasons, the claims of the ’295 patent were deemed directed to an abstract idea. Turning to its Step Two analysis, the court held that none of the recited physical components add an inventive concept sufficient to bring the abstract idea into the realm of patentability. Having failed both analytical steps of , the asserted claims were affirmed to be patent ineligible.