No. 3: Section 101 continues to develop for pharmaceutical and life science patents In a pair of decisions earlier this year, the U.S. Court of Appeals for the Federal Circuit applied the two-step Alice framework to life science patents. While the Boehringer v. Mylan ruling felt like a straightforward decision following Vanda, the later Illumina v. Ariosa case provided significant discussion, along with a Circuit Judge Jimmie Reyna dissent. In that decision, the court ultimately held that while the claimed methods utilize the natural phenomenon discovered by the inventors, they employed a physical process step to selectively remove fragments of cell-free fetal DNA and were therefore patent