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

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United States Court of Appeals, Federal Circuit

SIGNATURE FINANCIAL GROUP, INC. Defendant- file appeal

State had questioned statutory subject matter, got it called nonstatutory

  • now appella ct says it is statutory
  • next goes back to district courts to determine novelty, obviousness, etc...

United States District Court says patent invalid on the ground that the claimed subject matter is not encompassed by 35 U.S.C. § 101

  • REVERSED, say statutory subject matter


  • data processing system (the system) for implementing an investment structure which was developed for use in Signature's business as an administrator and accounting agent for mutual funds.
  • hubs and spokes financial services configuration
  • tax advantages to mutual funds
  • patenting method of managing who owns what, calculating returns, etc

inconsistent with Diehr rubber case?

  • doesn't produce anything new, other than efficiency, unlike new rubber product

like before, cant use "business method" like algorithm method

  • throwing them out for attribute of not being physical
  • but this is never stated in constitution
  • also its more and more relevant to current technology, so cant keep using it as standard for judgment
  • must follow code to make decision!

Arguing patent would cover too broad of material...

Whether the patent's claims are too broad to be patentable is not to be judged under § 101, but rather under §§ 102, 103 and 112. Assuming the above statement to be correct, it has nothing to do with whether what is claimed is statutory subject matter.

Claims should not be categorized as methods of doing business. Instead such claims should be treated like any other process claims