EB:ARRHYTHMIA RESEARCH TECHNOLOGY, INC. v. CORAZONIX CORP., 958 F.2d 1053 (1992)

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The Situation

Arrhythmia Research Tech. had a patent for a device which analyses electrocardiographic signals in order to determine certain characteristics of heart function which indicate a patients risk for ventricular tachycardia.

  • The patent involves mathematical calculations for interpretation of a hearts electrical signals
The patent was ruled invalid through failure to meet the terms of Section 101 (patentable subject matter) in a summary judgement by the District Court of Northern Texas.
  • Arrhythmia appeals the decision.

The Decision

The Appellate Court reverses the District Court opinion, ruling the patent valid.

The Reasoning

  • Computers are "generally recognized as devices of performing or impementing process steps, or serving as components of an apparatus, without negating patentability of the process or the apparatus" - computers are a tool for implementing a process, which does not negate patentability.
  • While claims "directed solely to an abstract mathematical formula or equation" are not patentable, those which are to "specific process or apparatus that is implemented in accordance with a mathematical algorithm" are patentable.
Freeman-Walter-Abele Test
  • (1)Is there an algorithm involved? (2)Is the invention more than just that algorithm? - If yes, and yes, then the claim is patentable.
  • Read this as: To be patentable, a claim must require "mo more than that the algorithm be 'applied in any manner to physical elements or process steps'"
    • When an algorithm is applied "in one or more steps of an otherwise statutory process claim" the claim is patentable.
  • Arrhythmia's claims are a "process" because the transformation of one electrical signal into another should be viewed in the same light as a transformation of material.


Concurring Opinion:

The "algorithm rule," as applied by the Freeman-Walter-Abele Test is a narrowing of the original statue of the 1952 Patent Act; in order to properly decide the case, the reasoning should apply directly to the Act.
  • The three excluded subject matters in the Act are "laws of nature, natural phenomena, and abstract ideas" - Arrythmia's invention is none of these things. It meets the qualifications of being a "process" (and also an "apparatus"), and thus it should be patentable.
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