1. Whether the Federal Circuit has wrongly applied this
Court's and its own precedent in disregarding key
functional limitations of the claims that implement the
improvement to the claimed invention over the prior
art in conducting a patent eligibility analysis under
35 U.S.C. §101.

2. Whether the Federal Circuit has wrongly usurped
the factfinder role and disregarded the requirement
to review the Patent Trial and Appeal Board's
factual findings on written description for substantial
evidence by sua sponte raising and ruling on a new
argument at the appellate hearing that was not
raised below and overrule the Board without the
Patent Owner or Board ever having an opportunity
to address it.

Whether the Federal Circuit wrongly disregarded functional limitations of patent claims in conducting a §101 patent eligibility analysis and whether the Federal Circuit usurped the factfinder role by sua sponte raising arguments regarding written description without allowing the Patent Trial and Appeal Board an opportunity to address them