State Street Bank & Trust Co. v. Signature Financial Group, Inc., 149 F.3d 1368 (1998)(Robins)

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Court of appeals

Lower court found patent invalid

Appeals court reversed hier judgement.

Invention:Data processing System for Hub and Spoke financial Services configuration

The patented invention relates generally to a system that allows an administrator to monitor and record the financial information flow and make all calculations necessary for maintaining a partner fund financial services configuration.

Claim 1 of the patent actually claims a machine, a physical data processing machine. Either way however, it still must be analyzed. The lower court ruled that this data processing was simply a mathematical algorithm combine with a business method.

Countering the math exception:

Similarly, in Arrhythmia Research Technology Inc. v. Corazonix Corp., 958 F.2d 1053, 22 USPQ2d 1033 (Fed.Cir.1992), we held that the transformation of electrocardiograph signals from a patient's heartbeat by a machine through a series of mathematical calculations constituted a practical application of an abstract idea (a mathematical algorithm, formula, or calculation), because it corresponded to a useful, concrete or tangible thing-the condition of a patient's heart.

Today, we hold that the transformation of data, representing discrete dollar amounts, by a machine through a series of mathematical calculations into a final share price, constitutes a practical application of a mathematical algorithm, formula, or calculation, because it produces “a useful, concrete and tangible result”-a final share price momentarily fixed for recording and reporting purposes and even accepted and relied upon by regulatory authorities and in subsequent trades.

Countering the busniess one:

We agree that this is precisely the manner in which this type of claim should be treated. Whether the claims are directed to subject matter within § 101 should not turn on whether the claimed subject matter does “business” instead of something else.