Arrhythmia Research Technology, Inc. v. Corazonix Corp. SKH

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  • Laws of nature, physical phenomena, and abstract ideas are not patentable.
  • Claims directed solely to an abstract mathematical formula or equation, including the mathematical expression of scientific truth or law of nature, whether directly or indirectly stated, are nonstatutory; whereas claims to a specific process or apparatus that is implemented in accordance with a mathematical algorithm will generally satisfy patent statute.
  • Under test for statutory subject matter when invention is described in terms of mathematical procedures, it is first determined whether mathematical algorithm is recited directly or indirectly in the claim; if so, it is next determined whether claimed invention as a whole is no more than the algorithm itself; this is, whether the claim is directed to a mathematical algorithm that is not applied to or limited by physical elements or process steps; such claims are nonstatutory; however, when mathematical algorithm is applied in one or more steps of an otherwise statutory process claim, or one or more elements of an otherwise statutory apparatus claim, requirements of patent statute are met.
  • Use of mathematical formulae or relationships to describe electronic structure and operation of an apparatus does not make it nonstatutory; when mathematical formulae are the standard way of expressing certain functions or apparatus, it is appropriate that mathematical terms be used.
  • Process and apparatus claims for invention directed to analysis of electrocardiographic signals in order to determine certain characteristics of heart function satisfied criteria for statutory subject matter.

  • We conclude that the claimed subject matter is statutory in terms of section 101. The judgment of invalidity on this ground is reversed.