As noted in previous posts, some going back over a year, it sure seems like the Supreme Court's Alice framework simply boils down, in the end, to whether the invention solves a technical problem. Of course you will find this notion nowhere in the Supreme Court's opinion, but the idea keeps showing up in Federal Circuit opinions, and now has popped up, explicitly, in a PTAB decision on an IBM application.
The invention relates to how to manage a cancelled Internet-based service provided to an Internet visitor by an Internet service provider. Claim 1 is rather long (see the opinion linked above) but the PTAB boils it down as being analogous to providing financial incentives, e.g., discounts, to retain existing customers. Whether or not that is a fair characterization is overshadowed by the greater question of whether the claimed invention solves a technical problem. From the PTAB:
Rather than addressing a technical problem, the claimed method and system are intended to address the business problem of customer retention (see Spec. 12 (explaining that customers comparison-shop for lower prices and are often willing to switch companies to get the cost savings; accordingly, it becomes vital that a service provider company manage customer discounts in an organized and strategic manner)). And, unlike the situation in DDR Holdings, there is no indication that the claimed “server computer” is used other than in its normal, expected, and routine manner to perform the abstract business practice of managing customer discounts following receipt of a cancellation request, which, as the court in DDR
Holdings explained, is not patent-eligible. DDR Holdings, 773 F.3d at 1256 (“[T]hese claims [of prior cases] in substance were directed to nothing more than the performance of an abstract business practice on the Internet or using a conventional computer. Such claims are not patent-eligible.”).
So, in case there was any doubt, patent drafters should endeavor to find a way so that the claims are set up to solve a technical problem, not merely address a business problem. This comports rather closely, at least on the surface, with the "technical effect" requirement often found in Europe.