In what we believe is a first since the Supreme Court Decision in Alice, the PTAB has denied CBM review based on Section 101.  In holding that the claims of USP 8,311,945, which are directed to processing paper checks, are directed to patent-eligible subject matter, the PTAB stated, “…we find that the basic, core concept of independent claim 1 is a method of processing paper checks, which is more akin to a physical process than an abstract idea.”  This indicates that physical steps, even if routine and mundane, could prevent a claim from being held as a non-eligible abstract idea. U.S. BANCORP v. SOLUTRAN, INC., CBM2014-00076.