The Federal Circuit upheld patents on digital image halftoning technology as patent-eligible subject matter, holding that mathematical algorithms applied to specific, practical technological problems are not so abstract as to be excluded from § 101, and cautioning against an overly rigid application of the abstract idea exception.
The Supreme Court held that the machine-or-transformation test is a useful but not exclusive test for patent eligibility under §101, and affirmed rejection of Bilski’s risk-hedging claims as unpatentable abstract ideas.
The Federal Circuit upheld Prometheus Laboratories’ patents on methods of optimizing thiopurine drug dosage by measuring metabolite levels in patients, finding the diagnostic methods patent-eligible under § 101 because the claimed steps transformed an article — a patient’s blood — by detecting specific metabolite concentrations.
The Federal Circuit sitting en banc held that the machine-or-transformation test is the definitive standard for determining whether a claimed process is patent-eligible under 35 U.S.C. § 101, rejecting a patent application on a business method for hedging commodity-trading risk.
The Federal Circuit held that business method patents are not categorically excluded from patentability — upholding a patent on a computerized financial data processing system for mutual fund management and establishing the ‘useful, concrete, and tangible result’ test for software and business method patent eligibility that dominated patent law until Alice v. CLS Bank (2014).