Gottschalk v. Benson, 409 U.S. 63 (1972)(Robins)

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To consider: Where are the boundarys of "process, machine, manufacture, or composition of matter"?

3 judges were not involved

Invention: They claimed a method for converting binary-coded decimal (BCD) numerals into pure binary numerals.

Decimal system: Accordingly, the numeral 1492 signifies (1X103.) + (4X102.) + (9X101.) + (2X100.).

Pure Binary:

Decimal (8) (4) (2) (1) Pure Binary

0 = 0 + 0 + 0 + 0 = 0000 1 = 0 + 0 + 0 + 20. = 0001 2 = 0 + 0 + 21. + 0 = 0010 3 = 0 + 0 + 21. + 20. = 0011 4 = 0 + 22. + 0 + 0 = 0100 5 = 0 + 22. + 0 + 20. = 0101 6 = 0 + 22. + 21. + 0 = 0110 7 = 0 + 22. + 21. + 20. = 0111 8 = 23. + 0 + 0 + 0 = 1000 9 = 23. + 0 + 0 + 20. = 1001 10 = 23. + 0 + 21. + 0 = 1010

BCD: Thus decimal 53 is represented as 0101 0011 in BCD, because decimal 5 is equal to binary 0101 and decimal 3 is equivalent to binary 0011. In pure binary notation, however, decimal 53 equals binary 110101. The conversion of BCD numerals to pure binary numerals can be done mentally through use of the foregoing table.


New inventions claimed to convert from BCD to pure. This required no new hardware and could be done mentally.

Court claimed process is vague and uses are known and unknown.

In O'Reilly v Morse, morse was allowed a patent for electromagnetism to produce distinguishable signs for telegraphy, however his claim for exclusive rights on using electromagetism were rejected. They claimed that with that cluase it didnt matter the process or machine that created the signal.

Similarly in the Telephone Cases, Bell was granted a patent because his invention was for the transmission of voice thorugh electricity within a certain device, not for all telephonic use of electricity.

It is argued that a process patent must either be tied to a particular machine or apparatus or must operate to change articles or materials to a "different state or thing." This is not Exclusive, as there is an exception in digital computers.

Judgement

One may not Patent an idea.

That would be the case if they allowed this patent. The patent would essentially patent an algorithm itself.

Court addresses that possibly laws should be extended to cover such cases, however they are simply interpreting the current law.