Arrhythmia Research Technology, Inc. v. Corazonix Corp., 958 F.2d 1053 (1992)(Robins)

US court of appeals(CAFC)

Earlier Court Patent declared invalid for failure in reguard to 101.

Judgement was reversed.

Arrythmia had patent.

Invention: analysis of electrocardiographic signals in order to determine certain characteristics of the heart.

People after heart attacks are at risk to a certain condition which can be prevented using dangerous drugs if necessary. Whether the patient needs it cna be determined with the electrocardiographic signals.

This is all based on the computer analyzing the data having a certain developed equation and applying it.

The Supreme Court has observed that Congress intended section 101 to include “anything under the sun that is made by man.” Diamond v. Chakrabarty with some qualifications.

Patents are not allowed to pre-empt the mathematical algorithm.

Freeman-Walter-Abele test

1. whether math algo is recited directly or indirectly in patent 2. whether the intention is only a formula, or is it limited by physical elements

rrhythmia Research states that the district court erred in law, and that the combination of physical, mechanical, and electrical steps that are described and claimed in the '459 patent constitutes statutory subject matter. Arrhythmia Research stresses that the claims are directed to a process and apparatus for detecting and analyzing a specific heart activity signal, and do not preempt the mathematical algorithms used in any of the procedures.

All 3 judges concurred.