How does the “particular transformation” consideration relate to the Alice/Mayo test?
The “particular transformation” consideration is an important factor within the Alice/Mayo test for patent eligibility, but it is not a standalone test. According to MPEP 2106.05(c):
If a claim passes the Alice/Mayo test (i.e., is not directed to an exception at Step 2A, or amounts to significantly more than any recited exception in Step 2B), then the claim is eligible even if it “fails” the M-or-T test.
Conversely, if a claim fails the Alice/Mayo test (i.e., is directed to an exception at Step 2A and does not amount to significantly more than the exception in Step 2B), then the claim is ineligible even if it passes the M-or-T test.
This means that while a particular transformation can be a strong indicator of eligibility, it must be considered alongside other factors in the overall Alice/Mayo framework.
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