On November 21, 2016, the Federal Circuit determined that a claimed invention that is “incidental to” or “complementary to” a financial activity is not necessarily within the legal standard of a “covered business method” (CBM) under Section 18(d) of the AIA.   The Court vacated and remanded the USPTO’s prior PTAB decision. Unwired Planet, LLC v. Google Inc., Fed. Cir., No. 2015-1812, 11/21/2016. Section 18(d) defines a CBM, among other things, as a patent claiming a method or apparatus used “in the practice, administration, or management of a financial product or service.” The patent claim at issue is directed to a system for restricting access to a wireless device’s location information.