What is the significance of the Mackay Radio case in determining a particular machine?

This page is an FAQ based on guidance from the Manual of Patent Examining Procedure. It is provided as guidance, with links to the ground truth sources. This is information only: it is not legal advice.

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.