Article: In re Bilski: new test for patent-eligible subject matter.

In an apparent effort to head off another potential reversal by the U.S. Supreme Court, the U.S. Court of Appeals for the Federal Circuit in its October 30 en banc decision in In re Bilski sought to limit the patent eligibility of certain "types" of processes, especially those relating to certain types of software and so-called "business methods." The court accomplished this by asserting that the sole test for determining whether a process claim is directed to patent-eligible subject matter was whether the process (1) is tied to a particular machine or apparatus, or (2) transforms a particular article into a different state or thing. In making this the sole test, the court ...

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