How does the use of a machine or transformation test affect patent eligibility?
The machine-or-transformation test can be a useful tool in determining whether a claim recites significantly more than a judicial exception. However, it is not the sole test for deciding whether an invention is a patent-eligible application of an abstract idea. According to MPEP 2106.05(f):
“Use of a machine or transformation of an article must impose meaningful limits on the claim’s scope to impart patent-eligibility. Use of a machine that contributes only nominally or insignificantly to the execution of the claimed method (e.g., in a data gathering step or in a field-of-use limitation) would not integrate a judicial exception or provide significantly more.”
This means that merely using a generic computer or machine to perform an abstract idea is not sufficient to make the claim patent-eligible. The machine must play a significant part in permitting the claimed method to be performed, rather than function solely as an obvious mechanism for permitting a solution to be achieved more quickly.
To learn more: