EB:ARRHYTHMIA RESEARCH TECHNOLOGY, INC. v. CORAZONIX CORP., 958 F.2d 1053 (1992)
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 Appellate Court reverses the District Court opinion, ruling the patent valid.
- 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.
- 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.