{"id":1327,"date":"2010-06-29T00:45:34","date_gmt":"2010-06-29T04:45:34","guid":{"rendered":"http:\/\/lotempiolaw.default.wp1.lexblog.com\/2010\/06\/uspto-sends-bilski-memo-to-patent-examiners\/"},"modified":"2021-02-20T05:23:50","modified_gmt":"2021-02-20T10:23:50","slug":"uspto-sends-bilski-memo-to-patent-examiners","status":"publish","type":"post","link":"https:\/\/www.lotempiolaw.com\/2010\/06\/patents\/uspto-sends-bilski-memo-to-patent-examiners\/","title":{"rendered":"USPTO Sends Bilski Memo to Patent Examiners"},"content":{"rendered":"

Almost immediately after the Supreme Court handed down the Bilski<\/a> decision Robert W. <\/a>Bahr<\/a>, Acting Associate Commissioner for Patent Examination Policy sent a memorandum to the patent examining corps<\/a> which gave guidance as to how the USTPO<\/a> examiners should interpret the case.<\/p>\n

Bahr told examiners to examine patent applications for compliance with section 101 using the machine-or-transformation test<\/strong> as a tool for determining whether the claimed invention is a process under section 101.<\/p>\n

If a claimed method meets the machine-or-transformation test, the method is likely patent-eligible under section 101 unless <\/strong>there is a clear indication that the method is directed to an abstract idea<\/strong>.<\/p>\n

Bahr summarized what the Supreme court decided in the short memo:<\/p>\n

The Supreme Court confirms section 101 specifies four independent categories of inventions and discoveries that are eligible for protection: process, machines, manufacturers, and compositions of matter.<\/p><\/blockquote>\n

The Supreme Court confirms that laws of nature, physical phenomenon and abstract ideas are not patentable subject matter.<\/p><\/blockquote>\n

The Supreme Court decided claims of Bilski not patent-eligible because under section 101 because they are an attempt to patent abstract ideas.<\/p><\/blockquote>\n

The Supreme Court indicated machine for transformation test is only a threshold inquiry and is not the sole test for patent eligibility of processes under 35 USC 101.<\/p><\/blockquote>\n

Significantly, the Supreme Court also indicated that a business method is at least in some circumstances eligible for patent under section 101.<\/p><\/blockquote>\n

Bahr concluded by saying an examiner should continue to examine patent applications for compliance with section 101 using “existing guidance” concerning the machine-or-transformation test.<\/p>\n

I tried to figure out what the existing guidelines are for the USPTO regarding the examination of a process claim. I found another memorandum dated January 7, 2009<\/a>, by John J. Love<\/a>, Deputy Commissioner for Patent Examination Policy, addressed to the Technology Center Directors and the Patent Examining Corps which explained that the Bilski <\/strong>machine-or-transformation <\/strong>test<\/strong> for a method claim is whether or not the claimed method is:<\/p>\n

    \n
  1. Tied to a particular machine or apparatus; or<\/li>\n
  2. Transforms a particular article to a different state or thing.<\/li>\n<\/ol>\n

    The “guidelines” go on to say that there are two corollaries to the machine-or-transformation test :<\/p>\n