prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What is the main topic of the text?

Read the following text and answer briefly.

Context 1: Ann's Mega Dub: 12/19/10 - 12/26/10
Got o have a penis to be an expert
Thursday on NPR's Fresh Air, Terry Gross wanted to talk film and music  Since women don't know a thing about either and aren't interested in either, Terry had to find men who were 'experts 'This is C I 's " Iraq snapshot Friday, December 24, 2010  Chaos and violence continue, Nouri's incomplete Cabinet continues to receive criticism, a father offers an 'excuse' for killing his own daughter, and more Marci Stone (US Headlines Examiner) reports, "Friday afternoon, Santa is currently in Baghdad, Iraq and on his next stop is Moscow, Russia, according to the 2010 NORAD Santa Tracker  The North American Aerospace Defense Command (NORAD) has been tracking Santa as he makes his annual journey throughout the world " Gerald Skoning (Palm Beach Post) quotes Santa saying, "We send our special wishes for peace and goodwill to all  That includes the people of Iraq, Afghanistan, Iran and North Korea " Please note that this is Santa's seventh trip to Iraq since the start of the Iraq War and, as usual, his journey was known in advance  No waiting until he hit the ground to announce he was going to Iraq -- the way George The Bully Boy Bush had to and the way US President Barack Obama still has to  In the lead up to Santa's yearly visit, many 'authorities' in Iraq began insisting that Christmas couldn't be celebrated publicly, that even Santa was banned  Gabriel Gatehouse (BBC News) quotes Shemmi Hanna stating, "I wasn't hurt but I wish that I had been killed  I wish I had become a martyr for this church, but God kept me alive for my daughters " Shemmi Hanna was in Our Lady of Salvation Church in Baghdad when it was assaulted October 31st and she lost her husband, her son, her daughter-in-law and her infant grandson in the attack  The October 31st attack marks the latest wave of violence targeting Iraqi Christians  The violence has led many to flee to northern Iraq (KRG) or to other countries  Zvi Bar'el (Haaretz) notes, "This week the Iraqi legislature discussed the Christians' situation and passed a resolution in principle to help families who fled  However, the parliament does not know where the Christians are, how many are still in Iraq, in their homes, and how many have found asylum in Iraqi Kurdistan " John Leland (New York Times) reports:The congregants on Friday night were fewer than 100, in a sanctuary built for four or five times as many  But they were determined  This year, even more than in the past, Iraqi's dwindling Christian minority had reasons to stay home for Christmas  "Yes, we are threatened, but we will not stop praying," the Rev  Meyassr al-Qaspotros told the Christmas Eve crowd at the Sacred Church of Jesus, a Chaldean Catholic church  "We do not want to leave the country because we will leave an empty space " Raheem Salman (Los Angeles Times) reports, "Rimon Metti's family will go to Christian services on Christmas Day, but his relatives will be praying for their own survival and wondering whether this is their last holiday season in Baghdad  If they had any grounds for optimism about the future of their faith in Iraq, it vanished this year amid repeated attacks on fellow believers " Shahsank Bengali (McClatchy Newspapers) adds, "Nearly two months after a shocking assault by Islamist militants, Our Lady of Salvation Catholic Church will commemorate Christmas quietly, with daytime mass and prayers for the dead, under security fit more for a prison than a house of worship  It is the same at Christian churches across Baghdad and northern Iraq, where what's left of one of the world's oldest Christian communities prepares to mark perhaps the most somber Christmas since the start of the Iraq war "Meanwhile Taylor Luck (Jordan Times) reports on Iraqi refugees in Jordan:Although the calendar will say December 25, for Theresa, Saturday will not be Christmas  There will be no cinnamon klecha cooling on the dining room table, no outdoor ceramic nativity scene, no readings of hymns with relatives  The 63-year-old Iraqi woman has even refused to put up Christmas lights in the crowded two-room Amman hotel apartment she has called home since fleeing Baghdad last month "There is no holiday spirit  All we have is fear," she said This holiday will instead mark another year without news from her 46-year-old son, who was kidnapped outside Baghdad in late 2006 From Turkey, Sebnem Arsu (New York Times -- link has text and video) notes the increase in Iraq refugees to the country since October 31st and quotes Father Emlek stating, "I've never seen as many people coming here as I have in the last few weeks  They also go to Lebanon, Jordan and Syria but it seems that Turkey is the most popular despite the fact that they do not speak the language " Jeff Karoub (AP) reports on the small number of Iraqi refugees who have made it to the US and how some of them "struggle with insomnia, depression and anxiety "One group in Iraq who can openly celebrate Christmas are US service members who elect to  Barbara Surk (AP) reports that tomorrow Chief Warrant Officer Archie Morgan will celebrate his fourth Christmas in Iraq and Captain Diana Crane is celebrating her second Christmas in Iraq: "Crane was among several dozen troops attending a Christmas Eve mass in a chapel in Camp Victory, an American military base just outside Baghdad " Marc Hansen (Des Moines Reigster) speaks with six service members from Iowa who are stationed in Iraq  Sgt 1st Class Dennis Crosser tells Hansen, "I certainly understand from reading the paper what's going on in Afghanistan and the attention definitely needs to be on the troops there  But everyone serving here in Operation New Dawn appreciates a little bit of attention as we finish this up "Today Jiang Yu, China's Foreign Minister, issued the following statement, "We welcome and congratulate Iraq on forming a new government  We hope that the Iraqi Government unite all its people, stabilize the security situation, accelerate economic reconstruction and make new progress in building its country " James Cogan (WSWS) reports:US State Department official Philip Crowley declared on Wednesday that Washington had not "dictated the terms of the government"  In reality, constant American pressure was applied to Maliki, Allawi, Kurdish leaders and other prominent Iraqi politicians throughout the entire nine-month process to form a cabinet  The US intervention included numerous personal phone calls and visits to Baghdad by both President Barack Obama and Vice President Joe Biden The key objective of the Obama administration has been to ensure that the next Iraqi government will "request" a long-term military partnership with the US when the current Status of Forces Agreement (SOFA) expires at the end of 2011  The SOFA is the legal basis upon which some 50,000 American troops remain in Iraq, operating from large strategic air bases such as Balad and Tallil and Al Asad  US imperialism spent billions of dollars establishing these advanced bases as part of its wider strategic plans and has no intention of abandoning them Cogan's only the second person to include the SOFA in his report  Some are impressed with the 'feat' of taking nearly ten months to form a government, stringing the country along for ten months while no decisions could go through  The editorial board of the Washington Post, for example, was full of praise yesterday  Today they're joined by Iran's Ambassador to Iraq, Hassan Danaiifar  The Tehran Times reports that Danaiifar was full of praise today hailing the "positive and final step which ended the 10-month political limbo in Iraq " However, Danaiifar was less pie-in-the-sky than the Post editorial board because he can foresee future problems as evidenced by his statement, "We may witness the emergence of some problems after one and half of a year -- for example, some ministers may be impeached " Of course, there are already many clouds on the horizon, even if Iranian diplomats and Post editorial boards can't suss them out  For example, Ben Bendig (Epoch Times) noted the objection of Iraq's female politicians to Nouri al-Maliki's decision to nominate only one woman (so far) to his Cabinet: "Some 50 female lawmakers went to the country's top leadership, the United Nations and the Arab League to voice their concern and desire for increased representation " BNO notes that protest and also that a group of Iraqi MPs are alleging that Iraqiya bought seats in the Cabinet via money exchanged in Jordan  UPI adds, "Maliki, a Shiite who has a long history of working with Tehran, has named himself acting minister of defense, interior and national security, three most powerful and sensitive posts in the government he is stitching together  Although Maliki appears to be bending over backward to accommodate rivals among Iraq's Shiite majority as well as minority Sunnis and Kurds in his administration in a spirit of reconciliation, he is unlikely to relinquish those ministries that dominate the security sector " DPA reports, "Sheikh Abdel-Mahdi al-Karbalaei, a confident of influential Shiite spiritual leader Ayatollah Ali al-Sistani, said that the new cabinet is 'below the standards' Iraqi citizens had hoped for and suggested it could prove to be weaker than the previous government " Ranj Alaaldin (Guardian) also spots clouds on the horizon:Lasting peace and stability depends on resolving outstanding disputes with the Kurds on oil, revenue-sharing, security and the disputed territories (Kirkuk in particular)  The Kurds, rather than exploiting their kingmaker position to take a stronger proportion of ministries in Baghdad (they are taking just one major portfolio – the foreign ministry), are instead banking on guarantees from Maliki to implement their list of 19 demands that includes resolving the above disputes in their favour They may have been naive, though  With their historical and federalist partners, the Islamic supreme council of Iraq in decline, the Kurds may be isolated in the new government – a government dominated by the nationalistic and centrist characteristics of the INM, the Sadrists and indeed State of Law Maliki may, therefore, turn out to be unable to grant concessions even if he wanted to and could use Osama Nujayfi, the new ultra-nationalist speaker of parliament and Kurdish foe, to absorb the Kurdish criticism and insulate himself from any attacks AP reports that Iraqi police sought out a 19-year-old woman because of rumors that she was working with al Qaida in Mesopotamia only to be greeted with the news that her father allegedly killed her and the father showed the police where he buried the woman       last month  The story begs for more than it offers  The most obvious observation is: what does it say that a woman's allegedly killed by her father and no one says a word for over a month? After that, it should probably be noted that there are many men in Iraq killing women who, no doubt, would love to also be able to pin the blame on al Qaida  In other violence, Reuters notes a house bombing in Haswa which claimed the life of Mohammed al-Karrafi, "his wife, two sons and a nephew" -- as well as injuring four more people, and a Samarra roadside bombing which claimed the lives of 2 police officers  DPA notes it was two homes bombed in Haswa and that the Samarra roadside bombing also injured four Iraqi soldiers  Jomana Karadsheh (CNN) reports, "Another policeman was wounded in Baghdad Friday night when a roadside bomb detonated by a police patrol, an Interior Ministry official told CNN "And we'll close with this from Peace Mom Cindy Sheehan's latest Al Jazeera column:The recent repeal of the US military policy of "Don't ask, don't tell" is far from being the human rights advancement some are touting it to be  I find it intellectually dishonest, in fact, illogical on any level to associate human rights with any military, let alone one that is currently dehumanising two populations as well as numerous other victims of it's clandestine "security" policies Placing this major contention aside, the enactment of the bill might be an institutional step forward in the fight for "equality"; however institutions rarely reflect reality Do we really think that the US congress vote to repeal the act and Obama signing the bill is going to stop the current systemic harassment of gays in the military?While I am a staunch advocate for equality of marriage and same-sex partnership, I cannot - as a peace activist - rejoice in the fact that now homosexuals can openly serve next to heterosexuals in one of the least socially responsible organisations that currently exists on earth: The US military It is an organisation tainted with a history of intolerance towards anyone who isn't a Caucasian male from the Mid-West  Even then I'm sure plenty fitting that description have faced the terror and torment enshrined into an institution that transforms the pride and enthusiasm of youth into a narrow zeal for dominating power relations And we'll close with this from Francis A  Boyle's "2011: Prospects for Humanity?" (Global Research):Historically, this latest eruption of American militarism at the start of the 21st Century is akin to that of America opening the 20th Century by means of the U S -instigated Spanish-American War in 1898  Then the Republican administration of President William McKinley stole their colonial empire from Spain in Cuba, Puerto Rico, Guam, and the Philippines; inflicted a near genocidal war against the Filipino people; while at the same time illegally annexing the Kingdom of Hawaii and subjecting the Native Hawaiian people (who call themselves the Kanaka Maoli) to near genocidal conditions  Additionally, McKinley's military and colonial expansion into the Pacific was also designed to secure America's economic exploitation of China pursuant to the euphemistic rubric of the "open door" policy  But over the next four decades America's aggressive presence, policies, and practices in the "Pacific" would ineluctably pave the way for Japan's attack at Pearl Harbor on Dec  7, 194l, and thus America's precipitation into the ongoing Second World War  Today a century later the serial imperial aggressions launched and menaced by the Republican Bush Jr  administration and now the Democratic Obama administration are threatening to set off World War III  By shamelessly exploiting the terrible tragedy of 11 September 2001, the Bush Jr  administration set forth to steal a hydrocarbon empire from the Muslim states and peoples living in Central Asia and the Persian Gulf under the bogus pretexts of (1) fighting a war against international terrorism; and/or (2) eliminating weapons of mass destruction; and/or (3) the promotion of democracy; and/or (4) self-styled "humanitarian intervention " Only this time the geopolitical stakes are infinitely greater than they were a century ago: control and domination of two-thirds of the world's hydrocarbon resources and thus the very fundament and energizer of the global economic system – oil and gas  The Bush Jr / Obama administrations have already targeted the remaining hydrocarbon reserves of Africa, Latin America, and Southeast Asia for further conquest or domination, together with the strategic choke-points at sea and on land required for their transportation  In this regard, the Bush Jr  administration announced the establishment of the U S  Pentagon's Africa Command (AFRICOM) in order to better control, dominate, and exploit both the natural resources and the variegated peoples of the continent of Africa, the very cradle of our human species  This current bout of U S  imperialism is what Hans Morgenthau denominated "unlimited imperialism" in his seminal work Politics Among Nations (4th ed  1968, at 52-53): The outstanding historic examples of unlimited imperialism are the expansionist policies of Alexander the Great, Rome, the Arabs in the seventh and eighth centuries, Napoleon I, and Hitler  They all have in common an urge toward expansion which knows no rational limits, feeds on its own successes and, if not stopped by a superior force, will go on to the confines of the political world  This urge will not be satisfied so long as there remains anywhere a possible object of domination--a politically organized group of men which by its very independence challenges the conqueror's lust for power  It is, as we shall see, exactly the lack of moderation, the aspiration to conquer all that lends itself to conquest, characteristic of unlimited imperialism, which in the past has been the undoing of the imperialistic policies of this kind…  On 10 November 1979 I visited with Hans Morgenthau at his home in Manhattan  It proved to be our last conversation before he died on 19 July 1980  Given his weakened physical but not mental condition and his serious heart problem, at the end of our necessarily abbreviated one-hour meeting I purposefully asked him what he thought about the future of international relations  iraqbbc newsgabriel gatehousethe new york timesjohn lelandhaaretzzvi bar'elthe jordan timestaylor luckthe associated pressjeff karoubthe los angeles timesraheem salmancnnjomana karadsheh
Terry thinks she's a man
Yesterday on NPR's Fresh Air the hour went to a male TV critic  It's always a man with Terry  Always  And somebody tell her that a snotty, snooty TV critic really doesn't make for good programming This is C I 's "Iraq snapshot:" Thursday, December 23, 2010  Chaos and violence continue, Iraqi women make clear their displeasure over the Cabinet make up, Daniel Ellsberg and Veterans for Peace get some recognition, and more  Last Thursday a protest held outside the White House  One of the organizers was Veterans for Peace and Pentagon Papers whistle blower Daniel Ellsberg participated and spoke  Juana Bordas (Washington Post) advocates for both of them to be named persons of the year: Veterans for Peace and Daniel Ellsberg should be this year's person of the year because of their courage and bravery to stand up for all of us who believe that "war is not the answer " Moreover in a time of economic recession, the war machine is bankrupting our country  As John Amidon, a Marine Corps veteran from Albany asked at the White House protest, "How is the war economy working for you?"While unemployment rates hover near 10 percent, there is no doubt that the U S  economy and quality of life is faltering  Worldwide we are 14th in education, 37th in the World Health Organization's ranking on medical systems, and 23rd in the U N  Environmental Sustainability Index on being most livable and greenest benefits  There is one place we take the undeniable world lead  The US military spending accounts for a whopping 46 5 percent of world military spending--the next ten countries combined come in at only 20 7 percent  Linda Pershing (Truthout) reports, "Responding to a call from the leaders of Stop These Wars(1) - a new coalition of Veterans for Peace and other activists - participants came together in a large-scale performance of civil resistance  A group of veterans under the leadership of Veterans for Peace members Tarak Kauff, Will Covert and Elaine Brower, mother of a Marine who has served three tours of duty in Iraq, sponsored the event with the explicit purpose of putting their bodies on the line  Many participants were Vietnam War veterans; others ranged from Iraq and Afghanistan war veterans in their 20s and 30s to World War II vets in their 80s and older  They were predominately white; men outnumbered women by at least three to one  After a short rally in Lafayette Park, they formed a single-file procession, walking across Pennsylvania Avenue to the solemn beat of a drum  As they reached the police barricade (erected to prevent them from chaining themselves to the gate, a plan they announced on their web site), the activists stood shoulder to shoulder, their bodies forming a human link across the 'picture postcard' tableau in front of the White House " Maria Chutchian (Arlington Advocate) quotes, participant Nate Goldshlag (Vietnam veteran) stating, ""There was a silent, single file march around Lafayette Park to a drum beat  Then we went in front of the White House,  There were barricades set up in front of white house fence  So when we got there, we jumped over barricades and were able to get right next to the White House fence " Participant Linda LeTendre (Daily Gazette) reports: At the end of the rally, before the silent, solemn procession to the White House fence, in honor of those killed in Iraq and Afghan wars of lies and deceptions, the VFP played taps and folded an American flag that had been left behind at a recent funeral for the veteran of one of those wars  Two attendees in full dress uniform held and folded the flag  I had the image of all of the people who stood along the roads and bridges when the bodies of the two local men, Benjamin Osborn and David Miller, were returned to the Capital District  I thought if all of those people were here now or spoke out against war these two fine young men might still be with us I was blessed enough to be held in custody with one of those in uniform; a wonderful young man who had to move from his hometown in Georgia because no one understood why as a veteran he was against these wars  Even his family did not understand  (He remains in my prayers )Our plan was to attach ourselves to the White House fence until President Obama came out and talked to us or until we were arrested and dragged away  I don't have to tell you how it ended Mr  Ellsberg was one of 139 people arrested at that action  We've noted the protest in pretty much every snapshot since last Thursday  If something else comes out that's worth noting on the protest, we'll include it  We will not include people who don't have their facts and it's really sad when they link to, for example, Guardian articles and the links don't even back them up  It's real sad, for example, when they're trashing Hillary (big strong men that they are) and ripping her apart and yet Barack? "Obama's inaccurate statements"??? What the hell is that? You're inferring he lied, say so  Don't be such a little chicken s**t  It's especially embarrasing when you're grandstanding on 'truth ' Especially when you're the little s**t that clogged up the public e-mail account here in the summer of 2008 whining that you were holding Barack to a standard, then admitting that you weren't, then whining that if you did people would be mean to you  Oh, that's sooooooo sad  Someone might say something bad about you  The horror  You must suffer more than all the people in Iraq and Afghanistan combined  While the action took place in DC, actions also took place in other cities  We've already noted NYC's action this week, Doug Kaufmann (Party for Socialism & Liberation) reports on the Los Angeles action: Despite heavy rain, over 100 people gathered in Los Angeles on the corner of Hollywood and Highland to demand an end to the U S  wars on Afghanistan and Iraq  People came from as far as Riverside to protest, braving what Southern California media outlets have dubbed the "storm of the decade " The demonstration, initiated and led by the ANSWER Coalition, broke the routine of holiday shopping and garnered support from activists and even passers by, who joined in chanting "Money for jobs and education -- not for war and occupation!" and "Occupation is a crime -- Iraq, Afghanistan, Palestine!" Protesters held banners reading, "U S /NATO Out of Afghanistan!" and "Yes to jobs, housing and education -- no to war, racism and occupation!"Speakers at the demonstration included representatives of Korean Americans for Peace, ANSWER Coalition, KmB Pro-People Youth, Veterans for Peace, Party for Socialism and Liberation and National Lawyers Guild  Tuesday, Nouri al-Maliki managed to put away the political stalemate thanks to a lot of Scotch -- tape to hold the deal together and booze to keep your eyes so crossed you don't question how someone can claim to have formed a Cabinet when they've left over ten positions to be filled at a later date  One group speaking out is women  Bushra Juhi and Qassmi Abdul-Zahra (AP) report, "Iraq's female lawmakers are furious that only one member of the country's new Cabinet is a woman and are demanding better representation in a government that otherwise has been praised by the international community for bringing together the country's religious sects and political parties " As noted Tuesday, though represenation in Parliament is addressed in Iraq's Constitution, there is nothing to address women serving in the Cabinet  Aseel Kami (Reuters) notes one of the most damning aspects of Nouri's chosen men -- a man is heaing the Ministry of Women's Affairs  Iraqiya's spokesperson Maysoon Damluji states, "There are really good women who could do wel       they cannot be neglected and marginalized " Al-Amal's Hanaa Edwar states, "They call it a national (power) sharing government  So where is the sharing? Do they want to take us back to the era of the harem? Do they want to take us back to the dark ages, when women were used only for pleasure " Deborah Amos (NPR's All Things Considered) reports that a struggle is going on between secular impulses and fundamentalist ones  Gallery owner Qasim Sabti states, "We know it's fighting between the religious foolish man and the civilization man  We know we are fighting like Gandhi, and this is a new language in Iraqi life  We have no guns  We do not believe in this kind of fighting " Deborah Amos is the author of Eclipse of the Sunnis: Power, Exile, and Upheaval in the Middle East  Meanwhile Nizar Latif (The National) reports that distrust is a common reaction to the new government in Baghdad and quotes high school teacher Hussein Abed Mohammad stating, "Promises were made that trustworthy, competent people would be ministers this time around, but it looks as if everything has just been divided out according to sectarian itnerests  No attention has been paid to forming a functioning government, it is just a political settlement of vested interests  I'm sure al Maliki will have the same problems in his next four years as he had in the last four years " Days away from the ten months mark, Nouri managed to finally end the stalemate  Some try to make sense of it and that must have been some office party that the editorial board of the Washington Post is still coming down from judging by "A good year in Iraq " First up, meet the new Iraqi Body Count -- an organization that provides cover for the war and allows supporters of the illegal war to point to it and insist/slur "Things aren't so bad!" Sure enough, the editorial board of the Post does just that noting the laughable "civilian deaths" count at iCasualities  As we noted -- long, long before we walked away from that crap ass website, they're not doing a civilian count  They're noting how many deaths Reuters reports 
Context 2: \section{Introduction}\label{S1}

The multiple access interferences (MAI) is the root of user
limitation in CDMA systems \cite{R1,R3}  The parallel least mean
square-partial parallel interference cancelation (PLMS-PPIC) method
is a multiuser detector for code division multiple access (CDMA)
receivers which reduces the effect of MAI in bit detection  In this
method and similar to its former versions like LMS-PPIC \cite{R5}
(see also \cite{RR5}), a weighted value of the MAI of other users is
subtracted before making the decision for a specific user in
different stages \cite{cohpaper}  In both of these methods, the
normalized least mean square (NLMS) algorithm is engaged
\cite{Haykin96}  The $m^{\rm th}$ element of the weight vector in
each stage is the true transmitted binary value of the $m^{\rm th}$
user divided by its hard estimate value from the previous stage  The
magnitude of all weight elements in all stages are equal to unity 
Unlike the LMS-PPIC, the PLMS-PPIC method tries to keep this
property in each iteration by using a set of NLMS algorithms with
different step-sizes instead of one NLMS algorithm used in LMS-PPIC 
In each iteration, the parameter estimate of the NLMS algorithm is
chosen whose element magnitudes of cancelation weight estimate have
the best match with unity  In PLMS-PPIC implementation it is assumed
that the receiver knows the phases of all user channels  However in
practice, these phases are not known and should be estimated  In
this paper we improve the PLMS-PPIC procedure \cite{cohpaper} in
such a way that when there is only a partial information of the
channel phases, this modified version simultaneously estimates the
phases and the cancelation weights  The partial information is the
quarter of each channel phase in $(0,2\pi)$ 

The rest of the paper is organized as follows: In section \ref{S4}
the modified version of PLMS-PPIC with capability of channel phase
estimation is introduced  In section \ref{S5} some simulation
examples illustrate the results of the proposed method  Finally the
paper is concluded in section \ref{S6} 

\section{Multistage Parallel Interference Cancelation: Modified PLMS-PPIC Method}\label{S4}

We assume $M$ users synchronously send their symbols
$\alpha_1,\alpha_2,\cdots,\alpha_M$ via a base-band CDMA
transmission system where $\alpha_m\in\{-1,1\}$  The $m^{th}$ user
has its own code $p_m( )$ of length $N$, where $p_m(n)\in \{-1,1\}$,
for all $n$  It means that for each symbol $N$ bits are transmitted
by each user and the processing gain is equal to $N$  At the
receiver we assume that perfect power control scheme is applied 
Without loss of generality, we also assume that the power gains of
all channels are equal to unity and users' channels do not change
during each symbol transmission (it can change from one symbol
transmission to the next one) and the channel phase $\phi_m$ of
$m^{th}$ user is unknown for all $m=1,2,\cdots,M$ (see
\cite{cohpaper} for coherent transmission)  According to the above
assumptions the received signal is
\begin{equation}
\label{e1} r(n)=\sum\limits_{m=1}^{M}\alpha_m
e^{j\phi_m}p_m(n)+v(n),~~~~n=1,2,\cdots,N,
\end{equation}
where $v(n)$ is the additive white Gaussian noise with zero mean and
variance $\sigma^2$  Multistage parallel interference cancelation
method uses $\alpha^{s-1}_1,\alpha^{s-1}_2,\cdots,\alpha^{s-1}_M$,
the bit estimates outputs of the previous stage, $s-1$, to estimate
the related MAI of each user  It then subtracts it from the received
signal $r(n)$ and makes a new decision on each user variable
individually to make a new variable set
$\alpha^{s}_1,\alpha^{s}_2,\cdots,\alpha^{s}_M$ for the current
stage $s$  Usually the variable set of the first stage (stage $0$)
is the output of a conventional detector  The output of the last
stage is considered as the final estimate of transmitted bits  In
the following we explain the structure of a modified version of the
PLMS-PIC method \cite{cohpaper} with simultaneous capability of
estimating the cancelation weights and the channel phases 

Assume $\alpha_m^{(s-1)}\in\{-1,1\}$ is a given estimate of
$\alpha_m$ from stage $s-1$  Define
\begin{equation}
\label{e6} w^s_{m}=\frac{\alpha_m}{\alpha_m^{(s-1)}}e^{j\phi_m} 
\end{equation}
From (\ref{e1}) and (\ref{e6}) we have
\begin{equation}
\label{e7} r(n)=\sum\limits_{m=1}^{M}w^s_m\alpha^{(s-1)}_m
p_m(n)+v(n) 
\end{equation}
Define
\begin{subequations}
\begin{eqnarray}
\label{e8} W^s&=&[w^s_{1},w^s_{2},\cdots,w^s_{M}]^T,\\
\label{e9}
\!\!\!\!\!\!\!\!\!\!\!\!\!\!\!\!\!\!\!\!X^{s}(n)\!\!\!&=&\!\!\![\alpha^{(s-1)}_1p_1(n),\alpha^{(s-1)}_2p_2(n),\cdots,\alpha^{(s-1)}_Mp_M(n)]^T 
\end{eqnarray}
\end{subequations}
where $T$ stands for transposition  From equations (\ref{e7}),
(\ref{e8}) and (\ref{e9}), we have
\begin{equation}
\label{e10} r(n)=W^{s^T}X^{s}(n)+v(n) 
\end{equation}
Given the observations $\{r(n),X^{s}(n)\}^{N}_{n=1}$, in modified
PLMS-PPIC, like the PLMS-PPIC \cite{cohpaper}, a set of NLMS
adaptive algorithm are used to compute
\begin{equation}
\label{te1} W^{s}(N)=[w^{s}_1(N),w^{s}_2(N),\cdots,w^{s}_M(N)]^T,
\end{equation}
which is an estimate of $W^s$ after iteration $N$  To do so, from
(\ref{e6}), we have
\begin{equation}
\label{e13} |w^s_{m}|=1 ~~~m=1,2,\cdots,M,
\end{equation}
which is equivalent to
\begin{equation}
\label{e14} \sum\limits_{m=1}^{M}||w^s_{m}|-1|=0 
\end{equation}
We divide $\Psi=\left(0,1-\sqrt{\frac{M-1}{M}}\right]$, a sharp
range for $\mu$ (the step-size of the NLMS algorithm) given in
\cite{sg2005}, into $L$ subintervals and consider $L$ individual
step-sizes $\Theta=\{\mu_1,\mu_2,\cdots,\mu_L\}$, where
$\mu_1=\frac{1-\sqrt{\frac{M-1}{M}}}{L}, \mu_2=2\mu_1,\cdots$, and
$\mu_L=L\mu_1$  In each stage, $L$ individual NLMS algorithms are
executed ($\mu_l$ is the step-size of the $l^{th}$ algorithm)  In
stage $s$ and at iteration $n$, if
$W^{s}_k(n)=[w^s_{1,k},\cdots,w^s_{M,k}]^T$, the parameter estimate
of the $k^{\rm th}$ algorithm, minimizes our criteria, then it is
considered as the parameter estimate at time iteration $n$  In other
words if the next equation holds
\begin{equation}
\label{e17} W^s_k(n)=\arg\min\limits_{W^s_l(n)\in I_{W^s}
}\left\{\sum\limits_{m=1}^{M}||w^s_{m,l}(n)|-1|\right\},
\end{equation}
where $W^{s}_l(n)=W^{s}(n-1)+\mu_l \frac{X^s(n)}{\|X^s(n)\|^2}e(n),
~~~ l=1,2,\cdots,k,\cdots,L-1,L$ and
$I_{W^s}=\{W^s_1(n),\cdots,W^s_L(n)\}$, then we have
$W^s(n)=W^s_k(n)$, and therefore all other algorithms replace their
weight estimate by $W^{s}_k(n)$  At time instant $n=N$, this
procedure gives $W^s(N)$, the final estimate of $W^s$, as the true
parameter of stage $s$ 

Now consider $R=(0,2\pi)$ and divide it into four equal parts
$R_1=(0,\frac{\pi}{2})$, $R_2=(\frac{\pi}{2},\pi)$,
$R_3=(\pi,\frac{3\pi}{2})$ and $R_4=(\frac{3\pi}{2},2\pi)$  The
partial information of channel phases (given by the receiver) is in
a way that it shows each $\phi_m$ ($m=1,2,\cdots,M$) belongs to
which one of the four quarters $R_i,~i=1,2,3,4$  Assume
$W^{s}(N)=[w^{s}_1(N),w^{s}_2(N),\cdots,w^{s}_M(N)]^T$ is the weight
estimate of the modified algorithm PLMS-PPIC at time instant $N$ of
the stage $s$  From equation (\ref{e6}) we have
\begin{equation}
\label{tt3}
\phi_m=\angle({\frac{\alpha^{(s-1)}_m}{\alpha_m}w^s_m}) 
\end{equation}
We estimate $\phi_m$ by $\hat{\phi}^s_m$, where
\begin{equation}
\label{ee3}
\hat{\phi}^s_m=\angle{(\frac{\alpha^{(s-1)}_m}{\alpha_m}w^s_m(N))} 
\end{equation}
Because $\frac{\alpha^{(s-1)}_m}{\alpha_m}=1$ or $-1$, we have
\begin{eqnarray}
\hat{\phi}^s_m=\left\{\begin{array}{ll} \angle{w^s_m(N)} &
\mbox{if}~
\frac{\alpha^{(s-1)}_m}{\alpha_m}=1\\
\pm\pi+\angle{w^s_m(N)} & \mbox{if}~
\frac{\alpha^{(s-1)}_m}{\alpha_m}=-1\end{array}\right 
\end{eqnarray}
Hence $\hat{\phi}^s_m\in P^s=\{\angle{w^s_m(N)},
\angle{w^s_m(N)+\pi, \angle{w^s_m(N)}-\pi}\}$  If $w^s_m(N)$
sufficiently converges to its true value $w^s_m$, the same region
for $\hat{\phi}^s_m$ and $\phi_m$ is expected  In this case only one
of the three members of $P^s$ has the same region as $\phi_m$  For
example if $\phi_m \in (0,\frac{\pi}{2})$, then $\hat{\phi}^s_m \in
(0,\frac{\pi}{2})$ and therefore only $\angle{w^s_m(N)}$ or
$\angle{w^s_m(N)}+\pi$ or $\angle{w^s_m(N)}-\pi$ belongs to
$(0,\frac{\pi}{2})$  If, for example, $\angle{w^s_m(N)}+\pi$ is such
a member between all three members of $P^s$, it is the best
candidate for phase estimation  In other words,
\[\phi_m\approx\hat{\phi}^s_m=\angle{w^s_m(N)}+\pi \]
We admit that when there is a member of $P^s$ in the quarter of
$\phi_m$, then $w^s_m(N)$ converges  What would happen when non of
the members of $P^s$ has the same quarter as $\phi_m$? This
situation will happen when the absolute difference between $\angle
w^s_m(N)$ and $\phi_m$ is greater than $\pi$  It means that
$w^s_m(N)$ has not converged yet  In this case where we can not
count on $w^s_m(N)$, the expected value is the optimum choice for
the channel phase estimation, e g  if $\phi_m \in (0,\frac{\pi}{2})$
then $\frac{\pi}{4}$ is the estimation of the channel phase
$\phi_m$, or if $\phi_m \in (\frac{\pi}{2},\pi)$ then
$\frac{3\pi}{4}$ is the estimation of the channel phase $\phi_m$ 
The results of the above discussion are summarized in the next
equation
\begin{eqnarray}
\nonumber \hat{\phi}^s_m = \left\{\begin{array}{llll} \angle
{w^s_m(N)} & \mbox{if}~
\angle{w^s_m(N)}, \phi_m\in R_i,~~i=1,2,3,4\\
\angle{w^s_m(N)}+\pi & \mbox{if}~ \angle{w^s_m(N)}+\pi, \phi_m\in
R_i,~~i=1,2,3,4\\
\angle{w^n_m(N)}-\pi & \mbox{if}~ \angle{w^s_m(N)}-\pi, \phi_m\in
R_i,~~i=1,2,3,4\\
\frac{(i-1)\pi+i\pi}{4} & \mbox{if}~ \phi_m\in
R_i,~~\angle{w^s_m(N)},\angle
{w^s_m(N)}\pm\pi\notin R_i,~~i=1,2,3,4 \\
\end{array}\right 
\end{eqnarray}
Having an estimation of the channel phases, the rest of the proposed
method is given by estimating $\alpha^{s}_m$ as follows:
\begin{equation}
\label{tt4}
\alpha^{s}_m=\mbox{sign}\left\{\mbox{real}\left\{\sum\limits_{n=1}^{N}
q^s_m(n)e^{-j\hat{\phi}^s_m}p_m(n)\right\}\right\},
\end{equation}
where
\begin{equation} \label{tt5}
q^{s}_{m}(n)=r(n)-\sum\limits_{m^{'}=1,m^{'}\ne
m}^{M}w^{s}_{m^{'}}(N)\alpha^{(s-1)}_{m^{'}} p_{m^{'}}(n) 
\end{equation}
The inputs of the first stage $\{\alpha^{0}_m\}_{m=1}^M$ (needed for
computing $X^1(n)$) are given by
\begin{equation}
\label{qte5}
\alpha^{0}_m=\mbox{sign}\left\{\mbox{real}\left\{\sum\limits_{n=1}^{N}
r(n)e^{-j\hat{\phi}^0_m}p_m(n)\right\}\right\}



ground_truth: The main topic of the text is Iraq's politics and current situation.

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What algorithm is engaged in the PLMS-PPIC method?

Read the following text and answer briefly.

Context 2: 
\end{equation}
Assuming $\phi_m\in R_i$, then
\begin{equation}
\label{qqpp} \hat{\phi}^0_m =\frac{(i-1)\pi+i\pi}{4} 
\end{equation}
Table \ref{tab4} shows the structure of the modified PLMS-PPIC
method  It is to be notified that
\begin{itemize}
\item Equation (\ref{qte5}) shows the conventional bit detection
method when the receiver only knows the quarter of channel phase in
$(0,2\pi)$  \item With $L=1$ (i e  only one NLMS algorithm), the
modified PLMS-PPIC can be thought as a modified version of the
LMS-PPIC method 
\end{itemize}

In the following section some examples are given to illustrate the
effectiveness of the proposed method 

\section{Simulations}\label{S5}

In this section we have considered some simulation examples 
Examples \ref{ex2}-\ref{ex4} compare the conventional, the modified
LMS-PPIC and the modified PLMS-PPIC methods in three cases: balanced
channels, unbalanced channels and time varying channels  In all
examples, the receivers have only the quarter of each channel phase 
Example \ref{ex2} is given to compare the modified LMS-PPIC and the
PLMS-PPIC in the case of balanced channels 

\begin{example}{\it Balanced channels}:
\label{ex2}
\begin{table}
\caption{Channel phase estimate of the first user (example
\ref{ex2})} \label{tabex5} \centerline{{
\begin{tabular}{|c|c|c|c|c|}
\hline
\multirow{6}{*}{\rotatebox{90}{$\phi_m=\frac{3\pi}{8},M=15~~$}} & N(Iteration) & Stage Number& NLMS & PNLMS  \\
&&&&\\
\cline{2-5} & \multirow{2}{*}{64}& s = 2 &  $\hat{\phi}^s_m=\frac{3 24\pi}{8}$ & $\hat{\phi}^s_m=\frac{3 18\pi}{8}$ \\
\cline{3-5} & & s = 3 & $\hat{\phi}^s_m=\frac{3 24\pi}{8}$ & $\hat{\phi}^s_m=\frac{3 18\pi}{8}$ \\
\cline{2-5} & \multirow{2}{*}{256}& s = 2 &  $\hat{\phi}^s_m=\frac{2 85\pi}{8}$ & $\hat{\phi}^s_m=\frac{2 88\pi}{8}$ \\
\cline{3-5} & & s = 3 & $\hat{\phi}^s_m=\frac{2 85\pi}{8}$ & $\hat{\phi}^s_m=\frac{2 88\pi}{8}$ \\
\cline{2-5} \hline
\end{tabular} }}
\end{table}
Consider the system model (\ref{e7}) in which $M$ users
synchronously send their bits to the receiver through their
channels  It is assumed that each user's information consists of
codes of length $N$  It is also assumd that the signal to noise
ratio (SNR) is 0dB  In this example there is no power-unbalanced or
channel loss is assumed  The step-size of the NLMS algorithm in
modified LMS-PPIC method is $\mu=0 1(1-\sqrt{\frac{M-1}{M}})$ and
the set of step-sizes of the parallel NLMS algorithms in modified
PLMS-PPIC method are
$\Theta=\{0 01,0 05,0 1,0 2,\cdots,1\}(1-\sqrt{\frac{M-1}{M}})$,
i e  $\mu_1=0 01(1-\sqrt{\frac{M-1}{M}}),\cdots,
\mu_4=0 2(1-\sqrt{\frac{M-1}{M}}),\cdots,
\mu_{12}=(1-\sqrt{\frac{M-1}{M}})$  Figure~\ref{Figexp1NonCoh}
illustrates the bit error rate (BER) for the case of two stages and
for $N=64$ and $N=256$  Simulations also show that there is no
remarkable difference between results in two stage and three stage
scenarios  Table~\ref{tabex5} compares the average channel phase
estimate of the first user in each stage and over $10$ runs of
modified LMS-PPIC and PLMS-PPIC, when the the number of users is
$M=15$ 
\end{example}

Although LMS-PPIC and PLMS-PPIC, as well as their modified versions,
are structured based on the assumption of no near-far problem
(examples \ref{ex3} and \ref{ex4}), these methods and especially the
second one have remarkable performance in the cases of unbalanced
and/or time varying channels 

\begin{example}{\it Unbalanced channels}:
\label{ex3}
\begin{table}
\caption{Channel phase estimate of the first user (example
\ref{ex3})} \label{tabex6} \centerline{{
\begin{tabular}{|c|c|c|c|c|}
\hline
\multirow{6}{*}{\rotatebox{90}{$\phi_m=\frac{3\pi}{8},M=15~~$}} & N(Iteration) & Stage Number& NLMS & PNLMS  \\
&&&&\\
\cline{2-5} & \multirow{2}{*}{64}& s=2 &  $\hat{\phi}^s_m=\frac{2 45\pi}{8}$ & $\hat{\phi}^s_m=\frac{2 36\pi}{8}$ \\
\cline{3-5} & & s=3 & $\hat{\phi}^s_m=\frac{2 71\pi}{8}$ & $\hat{\phi}^s_m=\frac{2 80\pi}{8}$ \\
\cline{2-5} & \multirow{2}{*}{256}& s=2 &  $\hat{\phi}^s_m=\frac{3 09\pi}{8}$ & $\hat{\phi}^s_m=\frac{2 86\pi}{8}$ \\
\cline{3-5} & & s=3 & $\hat{\phi}^s_m=\frac{2 93\pi}{8}$ & $\hat{\phi}^s_m=\frac{3 01\pi}{8}$ \\
\cline{2-5} \hline
\end{tabular} }}
\end{table}
Consider example \ref{ex2} with power unbalanced and/or channel loss
in transmission system, i e  the true model at stage $s$ is
\begin{equation}
\label{ve7} r(n)=\sum\limits_{m=1}^{M}\beta_m
w^s_m\alpha^{(s-1)}_m c_m(n)+v(n),
\end{equation}
where $0<\beta_m\leq 1$ for all $1\leq m \leq M$  Both the LMS-PPIC
and the PLMS-PPIC methods assume the model (\ref{e7}), and their
estimations are based on observations $\{r(n),X^s(n)\}$, instead of
$\{r(n),\mathbf{G}X^s(n)\}$, where the channel gain matrix is
$\mathbf{G}=\mbox{diag}(\beta_1,\beta_2,\cdots,\beta_m)$  In this
case we repeat example \ref{ex2}  We randomly get each element of
$G$ from $[0,0 3]$  Figure~\ref{Figexp2NonCoh} illustrates the BER
versus the number of users  Table~\ref{tabex6} compares the channel
phase estimate of the first user in each stage and over $10$ runs of
modified LMS-PPIC and modified PLMS-PPIC for $M=15$ 
\end{example}

\begin{example}
\label{ex4} {\it Time varying channels}: Consider example \ref{ex2}
with time varying Rayleigh fading channels  In this case we assume
the maximum Doppler shift of $40$HZ, the three-tap
frequency-selective channel with delay vector of $\{2\times
10^{-6},2 5\times 10^{-6},3\times 10^{-6}\}$sec and gain vector of
$\{-5,-3,-10\}$dB  Figure~\ref{Figexp3NonCoh} shows the average BER
over all users versus $M$ and using two stages 
\end{example}


\section{Conclusion}\label{S6}

In this paper, parallel interference cancelation using adaptive
multistage structure and employing a set of NLMS algorithms with
different step-sizes is proposed, when just the quarter of the
channel phase of each user is known  In fact, the algorithm has been
proposed for coherent transmission with full information on channel
phases in \cite{cohpaper}  This paper is a modification on the
previously proposed algorithm  Simulation results show that the new
method has a remarkable performance for different scenarios
including Rayleigh fading channels even if the channel is
unbalanced 


Context 3: Xpp-pdf support utility
Xpp-pdf support utility
PATENT, TRADEMARK
& COPYRIGHT !
Reproduced with permission from BNA’s Patent,Trademark 11/20/09, 11/20/2009  Copyright ஽ 2009 by The Bu-reau of National Affairs, Inc  (800-372-1033) http://www bna com As the patent community anticipates a decision by the U S  Supreme Court on subject matter patentability, recent rulings by the Federal Circuit and the Board of Patent Appeals and Interferences suggest strategies for preparing method patent applications that will sur- vive the Federal Circuit’s ‘‘machine-or-transformation’’ test 
The Changing Landscape of Method Claims in the Wake of In re Bilski:What We Can Learn from Recent Decisions of Federal Courts and the Board ofPatent Appeals rulings on software-based and other business methodpatent applications 
On review before the high court is the en banc ruling ‘‘Pure’’ business methods are out  Algorithms by the U S  Court of Appeals for the Federal Circuit1 are out  Machines and data transformations that, in order to be eligible for patent protection, an in- ventive method must either be tied to a machine or re- While the patent community waits for the Supreme cite a transformation of an article 2 This ‘‘machine-or- Court’s decision in Bilski v  Kappos, No  08-964 (U S 
transformation’’ test replaced the Freeman-Walter- argued Nov  9, 2009) (79 PTCJ 33, 11/13/09), patent ap- Abele3 test and the ‘‘useful, concrete and tangible plicants seeking to write patentable claims are stuckwith trying to conform to the lower courts’ most recent 1 In re Bilski, 545 F 3d 943, 88 USPQ2d 1385 (Fed  Cir 
2008) (en banc) (77 PTCJ 4, 11/7/08) 
2 ‘‘The machine-or-transformation test is a two-branched Adriana Suringa Luedke and Bridget M  Hay- inquiry; an applicant may show that a process claim satisfies den are lawyers at Dorsey & Whitney, Min- § 101 either by showing that his claim is tied to a particular neapolis  Luedke can be reached at machine, or by showing that his claim transforms an article ’’ leudke adriana@dorsey com  Hayden can be reached at hayden bridget@dorsey com  3 In re Freeman, 573 F 2d 1237, 197 USPQ 464 (C C P A 
1978); In re Walter, 618 F 2d 758, 205 USPQ 397 (C C P A 
COPYRIGHT ஽ 2009 BY THE BUREAU OF NATIONAL AFFAIRS, INC 
result’’ inquiry advocated in State Street,4 each of gregating, and selling real estate property and claims which had been applied by the Federal Circuit and its reciting a method of performing tax-deferred real estate predecessor court in various cases, and both of which property exchanges were not statutory under Section 101  Since no machine was recited, the only issue be- In this article, we examine the 2008 decision of the fore the court was whether the claims met the ‘‘trans- Federal Circuit, federal district court decisions, and de- formation’’ prong of the Bilski test 13 The court held cisions of Patent and Trademark Office’s Board of that the claims ‘‘involve[d] only the transformation or Patent Appeals and Interferences  Based upon the out- manipulation of legal obligations and relationships’’ comes in these cases, we offer guidance as to what is that did not qualify under Bilski 14 patent-eligible under 35 U S C  § 101, strategies for pre- Concerning the recitation of the ‘‘creation of deed- senting methods in patent applications and claiming shares’’ in some of the claims, the court found that the these methods, and possible ‘‘fixes’’ for applications deedshares themselves were not physical objects, but drafted pre-Bilski that must now withstand scrutiny un- only represented intangible legal ownership interests in der the new machine-or-transformation test 
property 15 Therefore, the creation of deedshares wasnot sufficient to establish patent eligibility under Bil- A number of recent federal court and board decisions have applied the patent eligibility test set forth in Bilski, implemented step to an otherwise obvious method was not sufficient to avoid invalidity of the claim  In KingPharmeuticals Inc  v  Eon Labs Inc ,17 the district court held invalid claims to a method of increasing the oral Several cases have addressed (and rejected) claims bioavailability of metaxalone because the claims were obvious over the prior art asserted by the accused in- In In re Ferguson,6 the Federal Circuit reviewed the board’s rejection of claims directed to a method of mar- Two dependent claims added a step of informing the keting a product and a ‘‘paradigm’’ for marketing soft- patient of certain results, which the patentee argued ware as nonstatutory subject matter under Section was not obvious  The court rejected this argument, con- 101 7 The appellate court affirmed the board’s rejection, cluding that ‘‘[b]ecause the food effect is an inherent concluding that the method claims were neither tied to property of the prior art and, therefore, unpatentable, a particular machine or apparatus nor did they trans- then informing a patient of that inherent property is form a particular article into a different state or thing 8 The court defined a machine broadly as ‘‘a concrete The court also commented that the added step of in- thing, consisting of parts, or of certain devices or com- forming the patient did not meet the patent eligibility binations of devices,’’ which did not include the ‘‘shared standard set forth in Bilski because the step did not re- marketing force’’ to which the method claims were quire use of a machine or transform the metaxalone into a different state or thing 19 Notably, this conclusion The claims directed to a ‘‘paradigm’’ were non- runs counter to the Supreme Court’s instruction that statutory because the claims did not fall within any of claims are to be examined ‘‘as a whole’’ and not dis- the four statutory categories (machines, manufactures, sected into old and new elements and that are evaluated compositions of matter and processes)  Concerning the two closest possible categories, the court concluded Recent board decisions have been consistent with the that the claimed paradigm was not a process, because holdings of the federal courts  For example, in Ex parte no act or series of acts was required, and was not a Roberts,21 the board found ineligible under Section 101 manufacture, because it was not a tangible article re- a ‘‘method of creating a real estate investment instru- sulting from a process of manufacture 10 Concerning ment adapted for performing tax-deferred exchanges’’ the recitation of a ‘‘marketing company’’ in the para- because the claim did not satisfy either the machine or digm claims, the court concluded that the patent appli- cants did ‘‘no more than provide an abstract idea—a Similarly, in Ex parte Haworth,23 a method for ‘‘at- business model for an intangible marketing com- tempting to collect payments from customers having delinquent accounts concurrently with a partner that In Fort Properties Inc  v  American Master Lease owns the delinquent accounts’’ was found to be patent LLC,12 the California district court held that claims re- ineligible because the claim wording was ‘‘broad in that citing a series of transactions involving acquiring, ag- 1980); In re Abele, 684 F 2d 902, 214 USPQ 682 (C C P A 
4 State Street Bank & Trust Co  v  Signature Financial 16 See Ex parte Roberts , 2009-004444 at 4-5 (B P A I  June Group, 149 F 3d 1368, 1370, 47 USPQ2d 1596 (Fed  Cir  1998) 19, 2009) (holding a ‘‘method of creating a real estate invest- ment instrument adapted for performing tax-deferred ex- changes’’ patent ineligible as not passing the machine-or- 7 The court accepted the board’s definition of ‘‘paradigm’’ 17 593 F  Supp 2d 501 (E D N Y  2009) 
to mean ‘‘a pattern, example or model ’’ Id  at 1362 
20 See Diamond v  Diehr, 450 U S  175, 188 (1981) 
21 No  2009-004444 (B P A I  June 19, 2009) 
12 2009 WL 249205, *5 (C D  Cal  Jan  22, 2009) 
23 No  2009-000350 (B P A I  July 30, 2009) 
it refers generally to extending an offer, receiving an machine  Accordingly, the process claims       are not acceptance, and paying a commission’’ and did not in- voke, recite or limit the method of implementation us-ing any particular machine or apparatus 24 The court also evaluated similar claims that recited the use of a ‘‘comparator’’ to perform the recited pixel- B  Software Claims Not Expressly Tied to a ‘Particular by-pixel comparison and held that this recitation also did not mandate a machine 29 While the court acknowl-edged that software was offered as one ‘‘option,’’ the Other cases have addressed software methods where court concluded that the claimed function of the com- the claim language was either not expressly tied to com- parator could also be performed in one’s mind or on pa- puter hardware components or the ties to computer per such that a machine was not required  The court components were somewhat ambiguous  In several further noted that, even though the ‘‘comparator’’ was cases, courts have rejected the recitation of generic defined as a ‘‘device,’’ ‘‘the use of the term ‘device’ is computer components as sufficient to satisfy the ‘‘ma- not synonymous with machine ’’30 As a result, none of chine’’ prong of the Bilski test  A number of these deci- the claims at issue met the ‘‘machine’’ prong of the Bil- sions also addressed the ‘‘transformation’’ prong of the Concerning the ‘‘transformation’’ prong, the court re- In Research Corporation Technology Inc  v  Mi- lied in particular upon the Abele decision in expanding crosoft Corp ,25 the district court considered the patent the requirements of this test by requiring that the eligibility of method claims in six patents directed to claimed transformation process be both ‘‘(1) limited to methods of halftoning of gray scale images by using a transformation of specific data, and 2) limited to a vi- pixel-by-pixel comparison of the image against a blue sual depiction representing specific objects or sub- noise mask  Relying on the Federal Circuit’s Bilski stances ’’31 It then concluded that a number of the analysis as well as a decision of its predecessor court, patent claims did not meet the second prong of this ex- In re Abele,26 the judge concluded that a number of the panded test because the claims did not ‘‘require any vi- sual depiction or subsequent display’’ even though the transformation test set forth in Bilski 27 claimed method did transform specific image data 32 Concerning the ‘‘machine’’ prong, the district court The district court also found other claims patent- found that the pixel-by-pixel comparison recited in the eligible under Section 101 because these claims recited claims did not require the use of a machine, but could the use of the comparison data ‘‘to produce a halftoned ‘‘dictate[d] a transformation of specific data, and [were] be done on a sheet of paper using a pen  The com- further limited to a visual depiction which represents parison uses formulas and numbers to generate a bi- specific objects ’’33 Thus, the patent eligibility of the nary value to determine the placement of a dot at a claims turned on whether the claims recited the use of location  Formulas and numbers not tied to a particu- the transformed data to generate a display 
lar machine cannot be patented, under the machine In DealerTrack Inc  v  Huber,34 the district court prong, even with a field-of-use limitation because granted a summary judgment of invalidity under § 101 they represent fundamental principles, and to do so of patent claims directed to ‘‘a computer aided method’’ would preempt the entire field  The patent claims      
of managing a credit application reciting the following do not mandate the use of a machine to achieve their algorithmic and algebraic ends  Simply because adigital apparatus such as a computer, calculator, or [A] receiving credit application data from a remote the like could assist with this comparison does not render it patent eligible material  RCT’s argument [B] selectively forwarding the credit application data that a pixel by its nature is electronic and therefore to remote funding source terminal devices; necessitates a machine is a post solution argumentand the Court rejects it  The claim construction specifies that the comparison is of a value to a mask 29 The term ‘‘comparator’’ was construed by the court to be (or set of values) to determine whether the dot is a ‘‘device (or collection of operations, as in software) that com- turned on at a specific location  This process does pares an input number (called the operand) to a number pre- not require a particular machine  The Bilski test is stored in the comparator (called the threshold) and produces clear: the process claims must be tied to a particular as output a binary value (such as ‘‘0,’’ zero) if the input is alge-braically less than the threshold [the result of comparing anoperand against a fixed threshold and setting an operand less 24 Id  at 9-10  See also, e g , Ex parte Farnes, 2009-002770 than the threshold to one value and an operand greater than (B P A I  June 2, 2009) (rejecting a method claim for develop- or equal to the threshold to another value], and produces the ing a solution to a customer experience issue including steps opposite binary value (such as ‘‘1,’’ one) if the input is algebra- of: ‘‘identifying a target customer,’’ ‘‘defining a current cus- ically greater than or equal to the threshold ’’ Id  at *17 (em- tomer experience,’’ ‘‘summarizing values and benefits’’ to pro- vide to the customer, and ‘‘identifying metrics for measuring success’’); Ex parte Salinkas, 2009-002768 (B P A I  May 18, 31 Id  at *9  Notably, Bilski concluded that the Abele visual 2009) (finding patent ineligible a method of launching a depiction was ‘‘sufficient’’ to establish transformation (545 knowledge network involving ‘‘selecting an executive spon- F 3d at 963), while the Research Corporation court went fur- sor,’’ ‘‘forming a core team of experts,’’ and ‘‘providing pre- ther by making visual depiction ‘‘required’’ to establish trans- 25 2009 WL 2413623 (D  Ariz  July 28, 2009) (78 PTCJ 432, 26 684 F 2d 902, 214 USPQ 682 (C C P A  1982) 
34 2009 WL 2020761 (C D  Cal  July 7, 2009) (78 PTCJ 341, PATENT, TRADEMARK & COPYRIGHT JOURNAL [C] forwarding funding decision data from at least tation of ‘over the Internet’ suffices to tie a process one of the remote funding source terminal de- claim to a particular machine’’ and concluded that it vices to the remote application entry and display The internet continues to exist despite the addition [D] wherein the selectively forwarding the credit ap- or subtraction of any particular piece of hardware  It may be supposed that the internet itself, rather than [E] sending at least a portion of a credit application any underlying computer or set of computers, is the to more than one of said remote funding sources ‘‘machine’’ to which plaintiff refers  Yet the internet is an abstraction  If every computer user in the world [F] sending at least a portion of a credit application unplugged from the internet, the internet would to more than one of said remote funding sources cease to exist, although every molecule of every ma- sequentially until a finding [sic ] source returns a chine remained in place  One can touch a computer or a network cable, but one cannot touch ‘‘the inter- [G] sending       a credit application       after a prede- Additionally, the court found that the recitation of the [H] sending the credit application from a first remote internet in this case merely constituted ‘‘insignificant funding source to a second remote funding extra-solution activity’’ and therefore did not qualify as a ‘‘particular machine’’ under Bilski 41 ‘‘[T]ossing in In concluding that the claim did not satisfy the Bilski references to internet commerce’’ was not sufficient to machine-or-transformation test, the court held that the render ‘‘a mental process for collecting data and weigh- claimed central processor, remote application and dis- ing values’’ patent-eligible 42 Additionally, ‘‘limiting’’ play device, and remote funding source terminal device the claim to use over the Internet was not a meaningful could be ‘‘any device’’ and did not constitute a ‘‘’par- limitation, such that the claims ‘‘broadly preempt the ticular machine’ within the meaning of Bilski ’’35 The fundamental mental process of fraud detection using court relied upon several board decisions to support its associations between credit cards ’’43 premise that ‘‘claims reciting the use of general purpose processors or computers do not satisfy the test ’’36 claim,44 notwithstanding the Federal Circuit’s holding In Cybersource Corp  v  Retail Decisions Inc ,37 the in In re Beauregard,45 the district court concluded that district court held claims for ‘‘a method for verifying the ‘‘there is at present no legal doctrine creating a special validity of a credit card transaction over the Internet’’ ‘‘Beauregard claim’’ that would exempt the claim from and ‘‘a computer readable medium containing program the analysis of Bilski ’’ Moreover, ‘‘[s]imply appending instructions for detecting fraud in a credit card transac- ‘A computer readable media including program instruc- tion       over the Internet’’ invalid under § 101 based tions’ to an otherwise non-statutory process claim is in- upon the court’s interpretation of Bilski 
sufficient to make it statutory ’’46 Consequently, this Concerning the method claim, the court considered claim also failed the Bilski test 
both the ‘‘transformation’’ and ‘‘machine’’ prongs of the In at least one instance, the U S  International Trade Bilski test  In concluding that there was no transforma- Commission has interpreted the ‘‘machine’’ prong of tion, the court focused on the intangibility of the ma- Bilski less stringently than did the district courts in the nipulated data  According to the court, transformation cases discussed above  In In the Matter of Certain Video is limited to transformation of a physical article or sub- Game Machines and Related Three-Dimensional Point- stance  Accordingly, the method claim did not qualify ing Devices,47 the accused infringer filed a motion for because the data representing credit cards did not rep- summary judgment alleging that the asserted claims resent tangible articles but instead an intangible series impermissibly sought to patent a mathematical algo- of rights and obligations existing between the account rithm  According to the movant, the recitations of a ‘‘3D pointing device,’’ ‘‘handheld device,’’ or ‘‘free space Concerning whether the claimed method was tied to pointing device’’ were not sufficient to tie the claims to a particular machine, the court assessed whether ‘‘reci- a particular machine, but served ‘‘only to limit the field-of-use of the claimed mathematical algorithm and [did] not otherwise impart patentability on the claimed math- Id  at *3  The court relied upon the holdings in Ex parte Gutta, No  2008-3000 at 5-6 (B P A I  Jan  15, 2009) (stating In denying the motion for summary judgment, the ‘‘[t]he recitation in the preamble of ‘[a] computerized method ITC first noted that, ‘‘[w]hile the ultimate determination performed by a data processor’ adds nothing more than a gen- of whether the asserted claims are patentable under eral purpose computer that is associated with the steps of the § 101 is a question of law, the Federal Circuit has ac- process in an unspecified manner ’’); Ex parte Nawathe, No 
2007-3360, 2009 WL 327520, *4 (B P A I  Feb  9, 2009) (finding‘‘the computerized recitation purports to a general purpose processor [], as opposed to a particular computer specifically programmed for executing the steps of the claimed method ’’); and Ex parte Cornea-Hasegan, No  2008-4742 at 9-10 (B P A I 
Jan  13, 2009) (indicating the appellant does not dispute ‘‘the recitation of a processor does not limit the process steps to any 44 Claims having this format are called ‘‘Beauregard’’ specific machine or apparatus ’’)  The court also cited Cyber- claims and were found to not be barred by the traditional source Corp  v  Retail Decisions Inc , (discussed below), in sup- printed matter rule in In re Beauregard, 53 F 3d 1583, 1584, 35 port of its interpretation of the required ‘‘particular machine ’’ 37 620 F  Supp  2d 1068, 92 USPQ2d 1011 (N D  Cal  2009) 47 2009 WL 1070801 (U S I T C  2009) 
knowledged that ‘there may be cases in which the legal given a dataset of feature vectors associated with the question as to patentable subject matter may turn on subsidiary factual issues’ ’’ (citation omitted)  In con- for each binary partition under consideration, rank- struing the claims, the tribunal found that there was a ing features using two-category feature ranking; and genuine dispute as to whether the claimed ‘‘devices’’represented a ‘‘particular machine’’ under the Bilski while the predetermined number of features has not test and whether the claimed ‘‘two-dimensional rota- yet been selected: picking a binary partition p; tional transform’’ was merely a mathematical calcula- selecting a feature based on the ranking for binary tion or instead meant ‘‘changing the mathematical rep- resentation of a two-dimensional quantity from oneframe of reference to a differently-oriented frame of ref- adding the selected feature to an output list if not al- erence’’ as asserted by the patentee  Additionally, the ready present in the output list and removing the se- dispute over the meaning of the claimed ‘‘two- lected feature from further consideration for the bi- dimensional rotational transform’’ also raised a dis- puted issue as to whether this element recited a trans- Notably, while the independent claim failed the formation that would qualify under the ‘‘transforma- machine-or-transformation test, its dependent claim tion’’ prong of Bilski  Given these disputed issues, the was eligible because it recited, ‘‘further comprising us- ITC concluded that it was inappropriate to grant sum- ing the selected features in training a classifier for clas- mary judgment as to the patent eligibility of the claims 
sifying data into categories ’’ In view of the specifica- A similar conclusion was reached in Versata Soft- tion, the board indicated that the ‘‘classifier’’ was a par- ware Inc  v  Sun Microsystems Inc ,48 in which the dis- ticular machine ‘‘in that it performs a particular data trict court denied the defendant’s motion for summary classification function that is beyond mere general pur- judgment of invalidity under Section 101 based upon pose computing ’’53 The board also concluded that the the Bilski court’s refusal ‘‘to adopt a broad exclusion claim ‘‘transforms a particular article into a different over software or any other such category of subject state or thing, namely by transforming an untrained matter beyond the exclusion of claims drawn to funda- classifier into a trained classifier ’’54 In Ex parte Casati,55 the board reversed the examin- Less stringent ‘‘machine’’ prong analyses are also er’s Section 101 rejection of a method claim reciting: found at the board level  For example, in Ex parteSchrader,50 the board held patent-eligible under Bilski A method of analyzing data and making predictions, reading process execution data from logs for a busi- A method for obtaining feedback from consumers re- ceiving an advertisement from an ad provided by anad provider through an interactive channel, the collecting the process execution data and storing the process execution data in a memory defining a ware-house; creating a feedback panel including at least one feed-back response concerning said advertisement; and analyzing the process execution data; generatingprediction models in response to the analyzing; and providing said feedback panel to said consumers, using the prediction models to predict an occurrence said feedback panel being activated by a consumer to of an exception in the business process 
provide said feedback response concerning said ad-vertisement to said ad provider through said interac- In this case, giving consideration to the specification, which ‘‘unequivocally describes the data warehouse aspart of the overall system apparatus, and subsequent Here, the board found ‘‘interactive channel’’ to be descriptions describe the memory/warehouse device in part of an ‘‘overall patent eligible system of appara- terms of machine executable functions,’’ the board con- tuses’’ when viewed in the context of the specification, cluded that ‘‘one of ordinary skill in the art would un- which included ‘‘the Internet and World Wide Web, In- derstand that the claimed storing of process execution teractive Television, and self service devices, such as In- data in a memory defining a warehouse constitutes formation Kiosks and Automated Teller Machines ’’51 patent-eligible subject matter under § 101 because the In another recent decision, Ex parte Forman,52 the memory/warehouse element ties the claims to a particu- board found a ‘‘computer-implemented feature selec- tion method’’ including a ‘‘classifier’’ eligible under Other recent board decisions have reached the oppo- Section 101 because it satisfied both the machine and transformation prong  Here, the ‘‘classifier’’ was recitedin a dependent claim, in which its independent claim re-cited: 53 Id  at 13 
54 Id  See also Ex parte Busche, No  2008-004750 (B P A I 
A computer-implemented feature selection method May 28, 2009) (holding a process claim and a computer pro- for selecting a predetermined number of features for gram product claim, each reciting training a machine, ‘‘are di- a set of binary partitions over a set of categories rected to machines that have such structure as may be adaptedby training



ground_truth: The normalized least mean square (NLMS) algorithm.

prompt_front: Now, answer the following question based on the text below, only give me the answer and do not output any other words.

Question: What did the court in In re Ferguson conclude about the transformation prong of the Bilski test?

Read the following text and answer briefly.

Context 3: ’’) 55 No  2009-005786 (B P A I  July 31, 2009) 
48 2009 WL 1084412, *1 (E D  Tex  March 31, 2009) 
56 Id  at 7  See also Ex parte Dickerson, No  2009-001172 at 49 Citing Bilski, 545 F 3d at 959 n  23 
16 (B P A I  July 9, 2009) (holding claims that ‘‘recite a comput- 50 No  2009-009098 (B P A I  Aug  31, 2009) 
erized method which includes a step of outputting information from a computer       are tied to a particular machine or appa- 52 No  2008-005348 (B P A I  Aug  17, 2009) 
PATENT, TRADEMARK & COPYRIGHT JOURNAL implemented methods ineligible under the Bilski test transformation test applied to this type of claim 63 because the claims failed to tie the method steps to any Then, applying the Bilski test, the board concluded that concrete parts, devices, or combinations of devices  For the claim did not qualify  According to the board, the example, in Ex parte Holtz,57 the board found ineligible under Section 101 a ‘‘method for comparing file tree de-scriptions’’ because the claim ‘‘obtains data (a file struc- does not transform physical subject matter and is not ture), compares data (file structures), generates a tied to a particular machine        Limiting the claims change log, and optimizes the change log without tying to computer readable media does not add any practi- these steps to any concrete parts, devices, or combina- cal limitation to the scope of the claim  Such a field- tions of devices’’ and the ‘‘file structures’’ did not repre- of-use limitation is insufficient to render an other- Similarly, in Ex parte Gutta,58 the board held ineli- gible under § 101 a ‘‘method for identifying one or moremean items for a plurality of items       having a sym- II  The Current Scope of Patent Eligibility bolic value of a symbolic attribute,’’ concluding that the These recent cases establish that some types of meth- claim ‘‘computes a variance and selects a mean item ods are clearly patent-eligible under Section 101, others without tying these steps to any concrete parts, devices, clearly are not eligible, and yet others may be depend- or combinations of devices’’ and ‘‘symbolic values are ing on how they are described and claimed 
neither physical objects nor do they represent physicalobjects ’’ First, the eligibility of system and apparatus claims is largely unaffected by the Bilski decision, with the ca- In contrast to the district court’s decision in Cyber- veat that such claims may be more closely scrutinized source Corp , discussed supra, in a recent board deci- for compliance with Diamond v  Diehr and Gottschalk sion, Ex parte Bodin,59 ‘‘a computer program product’’ v  Benson, which prohibit patenting of a claim directed was found to be patent-eligible subject matter as being to ‘‘laws of nature, natural phenomena, [or] abstract embodied in a ‘‘computer readable medium ’’ Here, the board considered whether the phrase ‘‘recorded on the Also, methods that are performed at least in part by a recording medium’’ as it is recited in the body of the machine qualify for patent eligibility under Section 101 
claims was the same as ‘‘recorded on a computer- Thus, for example, some computer-implemented and readable medium ’’ Acknowledging the differences be- software-related inventions remain patentable as long tween a statutory claim to a data structure stored on a as they are properly described and claimed as being computer readable medium compared to a nonstatutory performed by a computer or computer components 
claim to a data structure that referred to ideas reflected The tie to a machine, however, cannot merely be im- in nonstatutory processes, the board stated: ‘‘[w]hen plicit based upon the description and context of the ap- functional descriptive material is recorded on some plication or general language in the preamble of the computer-readable medium, it becomes structurally claim  Instead, the use of a machine to perform one or and functionally interrelated to the medium and will be more of the claimed functions must be expressly de- statutory in most cases since use of technology permits scribed in the body of the claim so as to be a meaning- the function of the descriptive material to be real- ful limitation on the claim  If a method claim can be read in such a way that all functions can be performed Similarly, in Ex parte Azuma,61 a claim to a ‘‘com- by a human, it will likely not pass the machine prong of puter program product       comprising: a computer us- able medium’’ was found to be directed to statutory The ‘‘Interim Examination Instructions for Evaluat- subject matter under § 101 because the language ‘‘com- ing Subject Matter Eligibility Under 35 U S C  § 101’’ re- puter usable medium’’ referred to tangible storage me- cently issued by the Patent and Trademark Office con- dia, such as a server, floppy drive, main memory and firm that the recitation of a general purpose computer hard disk as disclosed by appellant’s specification, and is sufficient to satisfy Section 101 where the general did not ‘‘implicate the use of a carrier wave ’’ purpose computer is ‘‘programmed to perform the pro- In an older decision, Ex parte Cornea-Hasegan,62 cess steps,       in effect, becom[ing] a special purpose however, the Board seemingly came to the opposite conclusion, holding that a claim reciting ‘‘a computer Concerning data transformation, there seems to be readable media including program instructions which agreement of the Federal Circuit and at least one dis- when executed by a processor cause the processor to trict court that a method that is both limited to transfor- perform’’ a series of steps was not patent-eligible under mation of specific data and limited to a visual depiction Bilski  The board first determined that ‘‘analysis of a representing specific objects or substances qualifies un- ‘manufacture’ claim and a ‘process’ claim is the sameunder 63 Id  at 11 
57 No  2008-004440 at 12-13 (B P A I  Aug  24, 2009) 
65 Diamond v  Diehr, 450 U S  175, 185, 205 USPQ 488 58 No  2008-004366 at 10-11 (B P A I  Aug  10, 2009) 
(1980); Gottschalk v  Benson, 409 U S  63, 67, 175 USPQ 673 59 No  2009-002913 (B P A I  Aug  5, 2009) 
60 Id  at 10 (comparing In re Lowry, 32 F 3d 1579, 1583-84, 66 ‘‘Interim Examination Instructions for Evaluating Sub- 32 USPQ2d 1031 (Fed  Cir  1994) to In re Warmerdam, 33 F 3d ject Matter Eligibility Under 35 U S C  § 101,’’ U S  Patent and 1354, 1361-62, 31 USPQ2d 1754 (Fed  Cir  1994)) 
Trademark Office, Aug  24, 2009, at 6 (78 PTCJ 530, 8/28/09) 
61 No  2009-003902 at 10 (B P A I  Sept  14, 2009) 
The authors’ recent experiences with examiners suggest that 62 No  2008-004742 (B P A I  Jan  13, 2009) 
the examiners are following these instructions 
der Section 101 67 Thus, claims analogous to those in In Concerning claims directed to computer program re Abele68 in which ‘‘data clearly represented physical products, one district court has held that appending ‘‘A and tangible objects, namely the structure of bones, or- computer readable media including program instruc- gans, and other body tissues [so as to recite] the trans- tions’’ to an otherwise non-statutory process claim is in- formation of that raw data into a particular visual depic- sufficient to make it statutory 72 The board has also tion of a physical object on a display’’ are patent- held ineligible claims to ‘‘a computer readable me- dia ’’73 The board has, however, also upheld the eligibil-ity of ‘‘a computer program product’’ as being embod- ied in a computer readable medium 74 Given these in- Bilski has had a significant impact in eliminating consistent decisions, the patent eligibility of claims in patent protection for inventions that are performed en- tirely by humans or can be interpreted as such if read Concerning claims directed to generalized computer broadly  This includes claims that describe processes processing functions, several Board decisions suggest for creating or manipulating legal and financial docu- that, absent a tie to a concrete real-world application, ments and relationships  In this area in particular, many such claims are likely to be deemed an ‘‘algorithm’’ un- pending applications filed prior to Bilski are no longer der Benson and therefore held to be non-statutory  75 patent-eligible, and many issued patents are no longer Any recitation of a specific field of use for the claimed valid  This retroactive impact of the Bilski decision is process or use of the outcome of such processes are troubling, given the investment in these patents and ap- also more likely to be found ‘‘field-of-use’’ or ‘‘post- plications, which have now been rendered essentially solution activity’’ limitations insufficient to render the worthless despite the suggestion in the Federal Circuit’s claim patent-eligible  Thus, the more tied a claimed pro- earlier State Street decision, now overruled, that such cess is to tangible results or particular applications (not claims qualified for patent protection 
just fields of use), the more likely it is to qualify under Inventions that do not fit within the four statutory categories are also not patent-eligible  The Federal Cir-cuit and the board have rejected claims directed to ‘‘a III  Presenting and Claiming Methods in Patent signal,’’ ‘‘a paradigm,’’ ‘‘a user interface’’ and ‘‘a corr-elator’’ on the basis that these items did not qualify as a ‘‘machine, manufacture, composition of matter or pro- Several strategies for describing and claiming meth- cess’’ under § 101  70 There is also an increasing focus ods or processes in patent applications may avoid or on the tangibility of the claimed invention in that, to minimize potential Section 101 problems 
qualify as a ‘‘machine’’ or ‘‘manufacture’’ under Section First, the description provided in a patent application should include well-defined steps or functions associ-ated with method or process  For example, when the claims include ‘‘initiating’’ method steps, a description Remaining areas of uncertainty concerning the scope of well-defined physical steps or functions for initiating of Section 101 include (1) what qualifies under Bilski as should be provided, and a concrete item, machine, de- a ‘‘transformation of an article or data,’’ (2) whether vice, or component that is responsible for the initiating claims to computer programs (Beauregard claims) function should be identified  For claiming ‘‘identify- qualify, and (3) whether internal computer processing ing’’ method steps, provide specific parameters for functionality not tied to a specific application or tan- making the identification, such as according to a speci- fied measurement 76 Where data is involved, the source Concerning data transformation, other than Abele- and type of data should be specified 
style claims discussed above, what qualifies as a data or Also, drawings should be provided that depict the article transformation remains unclear  Claims that concrete item, device, component or combination have been held not to meet the transformation prong in- thereof, and each method or process step or function clude claims directed to the creation or manipulation of should be linked expressly to at least one item, device data representing an intangible series of rights and ob- or component in the drawings that performs the step or ligations (e g , credit card data) and claims directed to function  Broadening language indicating that other the transformation or manipulation of legal obligations components may also be used to perform the function and relationships  Beyond these specific examples, it is may also be included to avoid an unduly narrow inter- difficult to predict what will or will not qualify as a data or article transformation under Bilski 
The claims should affirmatively claim the device, ma- chine or component performing each step or function 
67 In re Bilski, 545 F 3d at 963; Research Corporation Tech- For computer or software-related inventions, the de- nologies, 2009 WL 2413623 at *9 
scription should specify that the software functionality 68 The claimed process involved graphically displaying vari- ances of data from average values wherein the data was X-rayattenuation data produced in a two dimensional field by a com- 72 Cybersource Corp , 620 F  Supp  2d at 1080 
puted tomography scanner  See In re Bilski, 545 F 3d at 962- 73 Cornea-Hasegan, No  2008-004742 
74 Ex parte Bodin, No  2009-002913 (B P A I  Aug  5, 2009) 
69 In re Bilski, 545 F 3d at 963 
75 E g , Ex parte Greene, No  2008-004073 (B P A I  Apr  24, 70 In re Nuijten 500 F 3d 1346, 1357, 84 USPQ2d 1495 (Fed 
2009); Daughtrey, No  2008-000202; Ex parte Arning, No 
Cir  2007) (74 PTCJ 631, 9/28/07) (signal); In re Ferguson, 558 2008-003008 (B P A I  Mar  30, 2009); Cybersource Corp , 620 F 3d 1359, 1366, 90 USPQ2d 1035 (Fed  Cir  2009) (77 PTCJ F  Supp 2d at 1080 (concerning claim 2) 
489, 3/13/09) (paradigm); Ex parte Daughtrey, No  2008- 76 See Brief of American Bar Association as Amicus Curiae 000202 (B P A I  Apr  8, 2009) (user interface); Ex parte Laba- Supporting Respondent, Bilski v  Kappos, No  08-964, ABA die, No  2008-004310 (B P A I  May 6, 2009) (correlator) 
Amicus Br  at 12-13 (U S  amicus brief filed Oct  2, 2009) (78 71 E g , Nuijten, 500 F 3d at 1356-7 
PATENT, TRADEMARK & COPYRIGHT JOURNAL is performed by a computer or computer components 
patent or published application, the option of importing Specificity as to the type of computer component per- subject matter into the specification is limited to ‘‘non- forming each function may be helpful in establishing essential’’ subject matter  In other words, the specifica- eligibility under the Bilski test 
tion can only be amended to disclose a machine for per-forming process steps as long as one skilled in the art IV  Fixing Pre-Bilski Applications to Meet the New would recognize from the original disclosure that the process is implemented by a machine  The key in mak- For patent applications filed prior to the Bilski deci- ing this type of amendment is avoiding (or overcoming) sion, it can be challenging to meet the new require- a rejection under 35 U S C  § 112, para  1, for lack of ments for patent eligibility, particularly when no ma- chine or transformations were expressly described in If incorporation by reference is not an option, a patent applicant may submit evidence, such as a decla- In some cases, there may be sufficient explicit de- ration by the inventor or a duly qualified technical ex- scription of a machine, e g , a computer, such that the pert, demonstrating that one skilled in the art would un- machine can be added into the body of the claims  For derstand the disclosed method to be one performed by example, patent applications for computer-related in- a machine  Unlike attorney argument, which can be dis- ventions sometimes contain a generic description of regarded, such evidence must be considered by the ex- computers that are used to perform the claimed method, and such a generic description may be suffi- One other option is to reformat the claims  Since Bil- cient to impart patent eligibility to the claims when the ski ostensibly does not apply to system and apparatus general-purpose computer is programmed to become a claims, in some instances it may be possible for an ap- plicant to convert his method claims into system claims For patent applications lacking in an explicit descrip- to avoid application of the Bilski test  This strategy, tion of any machine, however, the application may in- however, is unlikely to succeed where the patent speci- corporate by reference patents or publications that can fication does not describe such a system for implement- be used to bolster the specification and provide support ing the method and therefore does not provide the req- for the requisite claim amendments  When an applica- uisite disclosure of the claimed invention under Section tion incorporates by reference a U S  patent or pub- lished U S  patent application, any description from the incorporated references, whether or not the subject The future of the Bilski machine-or-transformation matter is ‘‘essential’’ to support the claims, may be im- test now rests with the Supreme Court  Regardless of ported into the specification  This option may enable the outcome of the appeal, however, it is clear that the importation of the requisite description of a machine, scope of statutory subject matter under Section 101 has which can then also be recited in the claims 77 When been narrowed  The Supreme Court now has a chance the document incorporated by reference is not a U S 
to clarify what has been excluded; it may even reject ormodify the Bilski machine-or-transformation test  How 77 Manual of Patent Examining Procedure, Eighth Ed , Rev 
this will affect the development and protection of cur- 7/2008, at § 608 01(P); see also 37 C F R  § 1 57 
rent and future technologies remains to be seen 
Source: http://www dorsey com/files/upload/luedke_bna_patent_journal_nov09 pdf
(resolução 404 2012 retificação 19062012)
RESOLUÇÃO Nº 404 , DE 12 DE JUNHO DE 2012 Dispõe sobre padronização dos procedimentos administrativos na lavratura de Auto de Infração, na expedição de notificação de autuação e de notificação de penalidade de multa e de advertência, por infração de responsabilidade de proprietário e de condutor de veículo e da identificação de condutor infrator, e dá outras providências 
Cheloidi e cicatrici ipertrofiche in dermatologia
a cura del dr  Antonio Del Sorbo - Specialista in Dermatologia e Venereologia antoniodelsorbo@libero it I Cheloidi di Alibert A volte una ferita anche apparentemente banale, guarisce lasciando una cicatrice voluminosa, rossastra e soprattutto antiestetica  I cheloidi sono cicatrici abnormi che possono far seguito a intervento chirurgico (es: tiroide, mammella, etc) e questo u



ground_truth: It required the transformation to be limited to specific data and a visual depiction representing specific objects or substances.