What are some examples of limitations that courts have described as merely indicating a field of use?

The MPEP 2106.05(h) provides several examples of limitations that courts have described as merely indicating a field of use or technological environment. Here are some key examples:

• Limiting drug administration to patients with a specific disorder (Mayo Collaborative Servs. v. Prometheus Labs. Inc.)
• Identifying participants in a hedging process as commodity providers and consumers (Bilski v. Kappos)
• Limiting the use of a mathematical formula to determining the circumference of a wheel (Parker v. Flook)
• Specifying that audit log data relates to transactions executed in a computer environment (FairWarning v. Iatric Sys.)
• Limiting virus screening to a telephone network or the Internet (Intellectual Ventures I v. Symantec Corp.)
• Limiting the collection and analysis of data to the electric power grid (Electric Power Group, LLC v. Alstom S.A.)
• Specifying that a budgeting abstract idea is implemented using a “communication medium” including the Internet and telephone networks (Intellectual Ventures I v. Capital One Bank)

These examples demonstrate that merely limiting an abstract idea or judicial exception to a particular field or technological environment is not sufficient to make a claim patent-eligible.

To learn more:

• Field of Use
• Technological Environment
• Patent Eligibility
• Court Cases
• Examples