15 in which the court iterated that what was important was not whether a mathematical algorithm was recited, but whether the process to which the invention was directed went beyond simply manipulating abstract ideas or natural phenomena. In the wake of these cases, patent practitioners were left with a series of convoluted rules to guide them in preparing patent applications directed to computer software. The earliest decision in this area held that systems for transacting business, such as bookkeeping systems, were unpatentable as being abstract and not residing in a process. However, this doctrine had a somewhat tortuous history because subsequent decisions, purportedly decided on the business method exception were, in fact, decided on other grounds. The exception has been berated as an unwarranted encumbrance to the definition of statutory subject matter.
Signature is the assignee of U.S. Patent No.
The Hub and Spoke configuration consolidates the costs of administering the funds and also provides the tax advantages of operating as a partnership. The system operates on a personal computer including software capable of performing the various functions recited in the claims of the '056 patent. Following unsuccessful efforts to negotiate a license agreement for the '056 patent, State Street brought a declaratory judgment action in Massachusetts District Court asserting invalidity, unenforceability, and non-infringement of the '056 patent, followed by a motion for partial summary judgment for failure to claim statutory subject matter under 35 U.S.C. 101, which was ultimately granted by the District Court. Under the second prong of the test, the Court found that the invention provided no further physical activity sufficient to warrant patentability. Only where the patent specification does not include supporting structure for the means recited in the claims should a machine claim be viewed as a process claim.