State Street Bank & Trust Co. v. Signature Financial Group, Inc. (JWB Class)

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The Case

  • Signature had patent, State Street ended the case on summary judgment (prosecution did not prove infringement)
  • Court of Appeals reversed the summary judgment and sent the case back down to the District Court
  • Patent involved system of mutual funds
    • Signature manages funds in a partnership with owners of mutual funds
    • Provides tax advantages, economy of scale
    • Patented method of calculating returns, ownership, etc.
  • If it results in a tangible concrete result, it is patentable
    • the modern interpretation of the physical change required by Diamond v. Diehr
    • outputting dollar amount is not an abstract result of an algorithm