Arrhythmia Research Technology, Inc. v. Corazonix Corp. (KyleR)

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  • 1992
  • patent involves a method of detecting and measuring aspects of an electrocardiograph signal to determine is someone is at risk for ventricular tachycardia
  • process is conducted with the aid of a digital computer and corresponding mathematical formulae
  • 35 USC 101 excludes "laws of nature, physical phenomena, and abstract ideas."
  • "claims to a specific process or apparatus that is implemented in accordance with a mathematical algorithm will generally satisfy section 101."

Determination of statutory subject matter: The Freeman-Walter-Abele test:

  1. determine whether a mathematical algorithm is recited directly or indirectly in the claim
  2. determine whether the claimed invention as a whole is no more than the algorithm itself
    • is the algorithm applied to or limited by physical elements or process steps?
  • this is not the only test and failure to satisfy this test may not always defeat claim

Decision: claim is held valid.

Concurring opinion:

  • the above test is vague

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