The Federal Circuit created controversy in 2020 over its application of the Supreme Court’s subject matter eligibility jurisprudence by finding a method of manufacturing an automobile propshaft ineligible for patent protection. See American Axle & Manufacturing, Inc. v. Neapco Holdings LLC, 966 F.3d 1347 (Fed. Cir. 2020).

According to the opinion, the claimed method was directed to an application of Hooke’s law, and thus patent ineligible. Soon after this decision, members of the Congressional Subcommittee on Intellectual Property asked the USPTO to publish a request for information on the current state of patent eligibility jurisprudence in the United States.