“An abstract idea can generally be described at different levels of abstraction.” Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1240 (Fed. Cir. 2016).
I really have no idea what to make of this quote from Judge Reyna’s opinion, but the PTAB Judges Appear to love it. More than 600 PTAB decisions have included the full quote over the past few years. The citation appears to come into play in two occasion: (1) when the PTAB makes a slight shift from what the examiner identified as the relevant abstract idea; and (2) when the claims appear to be directed to something very specific, but that still fails the Alice test.
In general, if the PTAB quotes Ameranth, it finds the claims abstract. Out of 100 recent PTAB eligibility decisions quoting Ameranth, only 1 sided with the applicant on eligibility grounds.