On June 21, 2013, in Ultramercial v. Hulu, No. 2010-1544, the Federal Circuit (Rader, Lourie (concur), O’Malley) reversed the district court’s grant of a Rule 12(b)(6) motion to dismiss on grounds that the computer-implemented invention was not patent eligible under § 101. This case provides incremental insight into the patent eligibility of computer-implemented inventions