What is the significance of the Mackay Radio case in determining a particular machine?
What is the significance of the Mackay Radio case in determining a particular machine?
The Mackay Radio case is significant in determining what constitutes a particular machine in the context of patent eligibility. The MPEP states:
“A claim that recites a mathematical calculation, formula, or equation, but does not sufficiently limit the use of the mathematical concept to a specific application, such as by limiting the claim to a particular technological environment or by reciting meaningful limitations beyond generally linking the use of the concept to a particular technological environment, is directed to an abstract idea.” (MPEP 2106.05(b))
The Mackay Radio case illustrates that merely reciting a mathematical formula in conjunction with a general-purpose computer or generic hardware is not enough to transform an abstract idea into a patent-eligible application. To be considered a particular machine, the claim must go beyond simply implementing a mathematical principle on a computer and must integrate the principle into a practical application or specific technological environment.
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