Gottschalk v. Benson (S.C. 1972)
New test - whether the patent claim containing a mathematical algorithm wholly preempts that algorithm.
- Ct. emphasized that ideas are not patentable.
- Patentable process claims
- One tied to a particular machine, or
- One causing physical transformation of an article
- Concluded that allowing a patent for this invention would be the same as allowing a patent for the fundamental idea behind it.