Today, the demand for modern technology is at an all time high. Mobile devices, for example, represent a vast and ever growing market, where companies invest significant resources into the research and development of new ideas and products. Ultimately, much of this research and development includes software development, and as a result there is a strong desire to protect those investments with software patents. However, under U.S. law, the question of what actually constitutes patentable “software” continues to be a difficult one for the courts. The recent decision in Alice Corp. v. CLS Bank Intl. is the Supreme Court’s latest attempt to shed light on this evolving area of law1