Michelle Lee: USPTO needs more Section 101 guidance

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Michelle Lee: USPTO needs more Section 101 guidance

michelle-lee-uspto-pic.jpg

At an appearance earlier this week at the Center for Strategic & International Studies (CSIS), USPTO director Michelle Lee said there needs to be more clarity and guidance in the post-Alice world

Picture of Michelle Lee

Lee was responding to a question Todd Dickinson of Novak Druce, who was in the audience and expressed frustration about the patentability of software and business method patents after the Supreme Court’s Alice decision. Dickinson pointed out that of the last approximately 20 cases decided by the Federal Circuit on Section 101 grounds, all but one found the patent at hand ineligible. Similarly, he said there have been twice as many patents rejected on 101 grounds since Alice and that all covered business method reviews with a final written decision have resulted in invalidation.

Lee agreed that there are still many unanswered questions about Section 101 jurisprudence post-Alice. She stressed that the Supreme Court made a point of saying that software and business method patents were not per se patent ineligible, and that the USPTO, like practitioners and the courts, are looking for clarity.

“The USPTO is at the front lines of this - we’re issuing guidance, we’ve gotten a lot of input from the public, but we all hope for greater clarity on an issue that is extremely complicated,” she said. “I think we’ll see a lot of developments, and I hope to see a lot of developments, in the foreseeable future in this area because there’s still quite a bit of ambiguity.”

Continuing the AIA’s work

Lee also spoke about the patent reform measures working their way through Congress. She spoke out in support of provisions to cut down on forum shopping, limit discovery in certain instances to prevent driving up costs and fee-shifting. On the last issue, she suggested that reform critics were overstating the effect fee-shifting rules, such as those in the Innovation Act, would have on patent holders with reasonable claims, even if those claims do not necessarily pan out in court.

“I don’t like to refer to it as a ‘loser pays’ system, I like to refer it as an ‘abuser pays’ system,” she said. Rather than fundamentally changing a part of the US legal system as some have argued, fee shifting proposals such as those in HR 9 [The Innovation Act in the House of Representatives] merely institute a level of “financial discipline” on both sides to prevent abuse. Lee stressed that the fee shifting provision will apply to a defendant as well if it unreasonably defends a case for longer than it should.

Perhaps in response to critics who argue that further calls for changes to the patent law are premature given that the effects of the AIA are still being discovered, Lee said that reform bills such as the Innovation Act deal with more with litigation, rather than the substantive patent law. In this sense then, patent reform efforts are continuing what the AIA started. She argued that many of the abuses are  a result of quirks in the American litigation system and its high costs, rather than loopholes in the patent laws.

“In the AIA we made a lot of good progress, we harmonised with the rest of the world going from first to invent to a first to file system…we got the PTO the ability to set its own fees and we got a whole set of post grant proceedings which have been pretty effective as a quality check,” she explained. “But the litigation-related concerns didn’t get addressed in the AIA and I think that’s an area that we’re all focused on.”

“I think what you’re seeing in the legislation currently before Congress is a lot in there dealing with streamlining discovery and requiring greater notice and greater specificity in the pleadings… and I think it’s right for Congress at this point to be focusing on litigation-related concerns.”

Video for the event, which included a panel discussion with Lee, Victoria Espinel of the Business Software Association, Michael Waring of the University of Michigan and moderator James Lewis of the CSIS can be found here.

more from across site and SHARED ros bottom lb

More from across our site

South Korea's One Law Partners is combining with boutique firm Minwho Law Group to leverage global expansion of K-content and build a broader offering spanning IP, tech and regulatory advisory work
Russell Kennedy's Gina Tresidder on juggling matters, delivering hard truths, and why IP ownership is rarely as simple as people think
Attorney Oran Friar and trainee attorney Harry Cunliffe at Reddie & Grose, share that patent filings for clinical LLMs are surging, but success in the UK and Europe hinges on demonstrating technical innovation
Implementers can use the UK courts to seek FRAND terms for patent pool licences
The first credible UPC spinouts are growing, and they are coming from elite patent litigation teams, suggesting specialist litigators may no longer need large platforms to compete
Voyage IP has hired a veteran IP leader from Spruson & Ferguson as its head of trademarks, as well as another consultant who will boost the firm’s commercial offering
Lawyers say unwritten appearance expectations can disproportionately affect women and junior talent, making proactive guidance a growing responsibility for law firm leaders
Apple’s lawsuit against OpenAI, which features Tier 1-ranked disputes firms on both sides, reflects how trade secrets litigation is becoming a prominent competition feature
Drew & Napier’s leadership appointments show one way full-service firms can back up claims about the strategic importance of IP
Strike-out application will hear claims that the copyright aspect of an IP infringement claim brought by a gambling and sports betting group should be dropped
Gift this article