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

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.

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

  • 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