Bonum Certa Men Certa

Bilski Case Analyses: Good News, Bad News

Supreme Court US, 2009



Summary: The Supreme Court of the United States (SCOTUS) provides ruling on the Bilski case; we take a preliminary look at the apparent outcome, with particular emphasis on the impact when it comes to software

YESTERDAY evening we posted the full text of the SCOTUS ruling regarding Bilski and added some immediate commentary. We assume that the huge number of analyses have been read by now and since we are not lawyers, we cannot offer anything too valuable or novel. Instead, here is a rundown encompassing some more coverage and opinions.



Over the weekend, just before this decision came, we found some of the following articles that are relevant to the subject:

i. Decision about the Second Amendment Case to be Ruled Today

After the decision of U.S. Supreme Court to regulate the Second Amendment case, Carl Bindenagel revealed the court’s record on earlier gun rights cases.


ii. Supreme Court Finale

Tom Goldstein of scotusblog.com believes that the Constitution will win out, but isn't sure how far the Court will go in terms of raising questions about firearms regulations.

That will be an important part of today's decision.

Three other cases will be decided today on student religious organizations on college campuses, a major case on software patents and whether a key part of the Sarbanes-Oxley (post Enron) law is constitutional.


iii. Will The Supreme Court Clean Up the Patent Mess?

I did my original patent posts in 2008, shortly after the Federal Circuit heard oral arguments in In Re Bilski, a case involving a "business method" patent. There was a growing consensus that the patent system was broken, and high expectations that the court would use it as an opportunity to reform the rules for patent eligibility. The decision was released later in the year, and it did just that, overturning the extremely permissive standard for patentability that had applied for the preceding decade.

The case is now before the Supreme Court, which is due to hand down its decison on Monday. Virtually everyone expects the high to affirm the Federal Circuit's rejection of Mr. Bilski's patent, but as always the important question is what's in the accompanying opinion. A narrow holding could simply rule out the most egregiously abstract business method patents (Mr. Bilski's "invention" consisted entirely of mental steps) while leaving the bulk of software and business method patents untouched. But if the Supreme Court is feeling more ambitious, it may try to draw a new line that invalidates many existing business method and maybe even deal with the sotware controversy.


iv. Patent Litigation Weekly: With Bilski, the Waiting Is the Hardest Part

Patent Watchtroll, a rude lawyer who has been lobbying for software patents, wrote about it and he seems to be supporting his position by warping/faking the oppositions' point of view or avoiding the mainstream opinion and instead asking a student. The headline says "Programmers Perspective", not "Programmer's Perspective" (making it seem like a talk on behalf of many). As the first comment says: "im calling you out, your a patent lawyer trying to support your position as a “programmer” using the pseudonym “andrew cole”"

There are other legal types who crave positive perspectives on monopoly (that's what a patent is). It is abundantly clear that lawyers are ruining science through the patent system, which to them is a form of tax on science.

Patently-O, which mostly attracts the legal types (with bias), ran this Bilski poll just before the decision arrived. When the decision finally came it correctly stated that:

The result is that the scope of patentable subject matter is certainly narrowed from its 1998 high-water-mark.


Yes, this is true and that's good news. Here is another take:

Supreme Court Rules Narrowly In Bilski; Business Method & Software Patents Survive



As I expected it appears that the Supreme Court has ruled somewhat narrowly in the Bilski case (pdf), which many had hoped would end the scourge of business method and software patents. Instead, the court effectively punted the issue. Technically it affirmed the overall decision from the Federal Circuit that Bilski's specific patent was invalid for being way too broad, but much more importantly for everyone else, it rolled back the Federal Circuit's "machine-or-transformation" test, which many believed effectively ruled out pure software patents. Instead, the court said that the courts "should not read into the patent laws limitations and condi-tions which the legislature has not expressed." In other words, business method and software patents survive.


The good news is that the "Supreme Court Throws Out Bilski Patent," as Ciaran/Slashdot summarised it.

ciaran_o_riordan writes "The US Supreme Court has finally decided the Bilski case (PDF). We've known that Bilski's patent would get thrown out; that was clear from the open mockery from the judges during last November's hearing. The big question is, since rejecting a particular patent requires providing a general test and explaining why this patent fails that test, how broad will their test be? Will it try to kill the plague of software patents? And is their test designed well enough to stand up to the army of patent lawyers who'll be making a science (and a career) of minimizing and circumventing it? The judges have created a new test, so this will take some reading before any degree of victory can be declared. The important part is pages 5-16 of the PDF, which is the majority opinion. The End Software Patents campaign is already analyzing the decision, and collecting other analyses. Some background is available at Late-comers guide: What is Bilski anyway?"


An interesting but forgotten fact is that Ginsburg attended the Bilski hearing despite her husband's death the prior day. This was pointed out by Groklaw, which offers an extensive summary (news survey) and links to coverage excepting news sources.

Anti-IBM lobbyist Florian Müller says that "the US Supreme Court accepts only one way to limit software patentability: new legislation from Congress [...] Only a decision to grant a patent on the Bilski application could have been any less restrictive"

Müller mass-mailed journalists (as usual) to spread his point of view. He wrote:

Please feel free to use in your reporting on the Bilski decision any of these comments. I'm the author of the FOSS Patents blog (and founder and former director of the NoSoftwarePatents campaign) on the Bilski decision and what it means for the patentability of software.

Here are a few select quotes, and further below the URL of my posting and the complete text.

"Unfortunately, the Supreme Court delivered an opinion that doesn't help the cause of partial or complete abolition of software patents at all."

"[T]he court's majority position is about the most liberal reasoning that it could have been. Only a decision to uphold the Bilski patent could have been any less restrictive.

"Simply put, the Supreme Court's decision does not do away with even one software patent that already exists, nor does it raise the bar for the future."

"The decision announced today makes it clear that a majority of the Supreme Court wanted to give the abolition of even only a small percentage of all software patents the widest berth possible."

"This US decision is even more disappointing when taking into account the global trend." [then mentions political process in New Zealand and court decision in Germany]

"The position that software patents should be abolished isn't nearly as popular among judges and politicians as it is in the free and open source software community."

The upcoming Defensive Patent License (DPL) is recommended at the end of the blog posting.

Here's the URL and the full text:

http://fosspatents.blogspot.com/2010/06/bilski-decision-major-disappointment.html


We still urge Müller to stop mass-mailing journalists. If you find the quotes above in some news articles, you'll know why. He tries using shortcuts to get his point heard and inject his name into articles (which he later cites with pride). We especially oppose his illusion that IBM is the root of all evil.

"I mentioned Microsoft in the same lobbying contexts as IBM," he told us separately, "on EU patent reform and today the reference to New Zealand. Plus I link in the righthand column to a slashdot op-ed that mentions Steve Ballmer.

"I also think(not at PC, writing this on phone, can't check) in a posting that I don't like their lobbying for software patents. Maybe the one on LinuxTag."

“Hopes and Dreams of "IP Sucks" Crowd Shattered - Cheers!”
      --ACT, Microsoft lobbyist
That hardly changes anything. In his book he wrote about Microsoft's lobbyists, but now he's just ignoring them for the most part (or ignoring their ties). But anyway, let's get back to In Re Bilski

Müller showed us that Microsoft lobbying group ACT is "jubilant over SCOTUS decision" (he didn't mention the Microsoft connection)

ACT wrote: "#SCOTUS Upholds Software Patents. Hopes and Dreams of "IP Sucks" Crowd Shattered - Cheers! - ACT Blog - http://bit.ly/dkzLay #bilski"

One reader showed us that ACT's Mike Sax (seen here) has just had an article published about him in Standaard. He admits being supported by Microsoft (while evidently pretending to serve small businesses).

Het dunbevolkte Oregon met zijn wilde natuur en wouden is niet meteen de meest voor de handliggende locatie voor een technologiebedrijf. Maar Sax is niet van plan te verhuizen. 'Het zegt veel over technologie dat je niet vanuit een metropool hoeft te werken om toch succesvol te zijn. Idealiter heb je dan ook werknemers die op afstand werken en die daardoor een hoge levenskwaliteit behalen omdat ze in kleine steden wonen, dicht bij hun familie, zonder dat ze hun carrière moeten opgeven.' Een betoog dat niet toevallig aansluit bij dat van de Association for Competitive Technology (ACT), een organisatie die Sax in 1998 oprichtte en die streeft voor de belangen van kleinere technologiebedrijven -al zijn ook grotere ondernemingen zoals Oracle en Microsoft steunend lid. Het is voor ACT dat Sax opnieuw Brussel bezoekt, om bij Europarlementsleden te pleiten voor een geharmoniseerde privacy- en arbeidswetgeving en een Europees patent.


The last sentence says that Sax is visiting Brussels again, pushing for MEPs to call for the back door to software patents ('harmonisation' or 'European patent'). Who are they kidding? They are Microsoft's lobbyists and they push for software patents in Europe. Is Müller paying attention at all? Nope. His blog post about the Bilski decision is a defeatist one and it's titled "Bilski decision a major disappointment: doesn't invalidate even one software patent"

The Supreme Court of the United States (SCOTUS) has finally handed down its opinion in re Bilski, a business method patent case.


Here is more from Patently-O:

Although Bilski's claims were held unpatentably abstract, the Supreme Court has re-affirmed that the door to patent eligibility should remain broad and open.


The FFII writes that "Bilski's business patent [is] rejected by the Supreme Court but no MoT-Test for the rest of US" (machine-or-transformation test).

We've been sent a lot of E-mail following this milestone decision and one of them sought publication that related to the MoT-Test:

I know you've been actively following the Bilski case on TechRights. In the wake of this morning's decision, I wanted to pass on some commentary from Barbara Rogan, the Chief Legal Counsel for LogLogic. Barbara has been closely monitoring the decision due to its implications on the tech industry and startups. While the Supreme Court's decision affirms the Federal Court's ruling, it also raises a number of other questions in the area of process patents.

Barbara's commentary below:

What’s Still To Be Decided:

What is a Machine?
  • The Supreme Court agrees with the Federal Circuit that merely using an abstract idea in “a particular technological environment” or by adding “insignificant postsolution [sic] activity” does not transform an otherwise unpatentable invention into a patentable invention.
    • In Bilski, the Federal Circuit ruled that the connection of the process to a machine or apparatus must be more than just “insignificant extra-solution activity” meaning that the machine must be more than a “throw-in” to make the process patentable.


    • In its brief to the Supreme Court, the Respondents argue that using a general purpose machine (i.e. a calculator or a telephone) would not be sufficient for to turn an otherwise non-patentable process into a patentable process.
  • In Yahoo!’s Amicus Curiae brief, Yahoo! Worries that with the Machine or Transformation, processes which are carried out over the Internet (a general purpose series of machines) may fail this test, thus leaving out from patent protection all Internet based processes.


  • Yahoo!’s concern is not theoretical. While the Bilski case was pending in the Supreme Court, the District Court in Northern California in Cybersource Corporation v. Retail Decisions, used the Machine or Transformation Test to find that the defendant’s motion for summary judgment in a patent infringement suit should be granted because the patent was likely on unpatentable subject matter. The process patent in question was an Internet based process patent.
    • In light of Bilski decision, it would seem that the District Court should re-examine its ruling as the Supreme Court indicated the Machine or Transformation test is NOT the exclusive test for determining process invention patentability.
  • Another question that is open and needs to be decided is whether programming a general purpose machine to do a specific task is sufficient to overcome the requirement that the machine not contribute in an “insignificant extra-solution activity” manner.


What is “Transformation” in the Digital Age?
  • The meaning of transformation as it applies to digital information has yet to be decided. In oral arguments, Justice Sotomayor suggests that electronic signals may be a “substance” which would differentiate it from a pure process completed outside of a computer. Based on this reasoning, a viable argument could be made that the electronic processes transform the information from one type or state into another type or state. This would free digital technology patents from the need to be tied to a machine for the purposes of obtaining a patent.
What inventions might be still be patentable if they fail the Machine or Transformation Test?



Justice Stevens tried to do that right thing, but upon his retirement there is generally a feeling that he didn't have enough power to counter his peers and knock out software patents.

In April, the Supreme Court's most senior justice, John Paul Stevens, announced his retirement. Since then, hundreds of articles have been written about his career and his legacy. While most articles focus on "hot button" issues such as flag burning, terrorism, and affirmative action, Stevens's tech policy record has largely been ignored.

When Justice Stevens joined the court, many of the technologies we now take for granted—the PC, packet-switched networks, home video recording—were in their infancy. During his 35-year tenure on the bench, Stevens penned decisions that laid the foundation for the tremendous innovations that followed in each of these areas.

[...]

The high court took a renewed interest in patent issues when John Roberts was elevated to Chief Justice, but the court hasn't squarely addressed the software patent issue. The closest they came was in today's Bilski decision, in which the majority handed down a narrow ruling that invalidated the specific patent at issue in the case but declined to articulate a clear standard for patent eligibility.


It is possible to see Stevens' portions in this ruling. The following Bilski analysis highlights a portion that says: "But this fact does not mean that unforeseen innovations such as computer programs are always unpatentable" (covered in [1, 2, 3]). The bottom line is -- as Stephen Shankland put it -- the Supreme Court sidesteps software patent issue. But it doesn't make it a loss for software freedom; it just leaves the USPTO in a limbo.

Recent Techrights' Posts

An American War on GNU/Linux, Software Freedom, and British Investigative, Science-Based Reporting - Part III - Very Strong Legal Basis for an Appeal
The case is now being escalated to a Foreign Secretary and former Deputy Prime Minister
No Slop Found in RSS Feeds, Only in Google News
No slopfarm will survive for very long, certainly it'll go bust as soon as readers (if it had any) know what it is
What the Solicitors Regulation Authority (SRA) and Action Fraud UK Have in Common
Don't let London become the world's "crime capital"
Dr. Andy Farnell on How GAFAM, NVIDIA and Others Lie to People Via the Sponsored Media to Prop Up Lies Under the Guise of "AI"
Lots of key aspects are covered
Richard Stallman Gives Talk in 20 Hours at Ostschweizer Fachhochschule Campus in Rapperswil-Jona
The talk is in English
 
RMS is 73 Next Week
Richard Matthew Stallman (RMS) turns 73 exactly 7 days from now
Iran & FSFE: blackmailing women, from football to the French Government (CNIL)
Reprinted with permission from Daniel Pocock
Police investigations, lawsuits & Debian leader election candidate shortage
Reprinted with permission from Daniel Pocock
Richard Stallman (RMS) Has Defeated Cancel Culture, a Mostly American Phenomenon
RMS is talking now
Links 09/03/2026: Many Security Breaches and a Pandemic of Censorship
Links for the day
People Who Work or Worked at IBM Hate It
bluewashing is only the first step
Richard Stallman (RMS) Talks in 30 Minutes, Next Stop Bern (Last Stop)
We assume he'll travel back to Boston after that
IBM's Fedora as a Booster of Slop Disguised as Code or Computer Programs
Maybe we should also stop seeing a doctor and instead ask chatbots about symptoms?
Richard Stallman (RMS) Talk Five Hours From Now
there is growing recognition for what he really did for everybody
EPO Strike 10 Days From Now, Planning Assembly Tomorrow, Last Couple of Strikes Had High Participation Rates (1,500-1,600 Staff Went on Strike)
The next strike is in 10 days' time and then there will be another strike
Links 09/03/2026: GAFAM Outsourcing, "MAGA Political Meddling" in EU, Indonesia Bans Social Control Media for Children Under 16
Links for the day
Using Slop (and Slop in Articles) to Attack Copyleft 'on Budget'
This article is pure BS from an anti-GPL and anti-RMS 'activist'
Why The Register MS Sold Out to Microsoft: They're Losing Lots of Money, The Register MS is Bleeding to Death, Based on Its Own Financial Records
With over 6 million pounds in debt (nearly 10 million US dollars) we guess it's likely some other company will take over the site (if it deems it worthwhile)
Microsofters' SLAPP Censorship - Part 7 Out of 200: Like With the Serial Strangler From Microsoft, Misuse of UK-GDPR to Try to Hide Embarrassing Facts
They do and say really bad things, then allege it's a "privacy violation" to mention those things
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Sunday, March 08, 2026
IRC logs for Sunday, March 08, 2026
Gemini Links 09/03/2026: Exponentials and Tailscale
Links for the day
Sloppyleft
Article by Alexandre Oliva
Hard to Replace 'Human Touch'
The reason many people insist on using GNU
The Slop Companies Gamble at Our Economy's Expense and They Know It's a Losing Bet (So It's a de Facto Robbery)
The crash of this bubble isn't just inevitable, it's already happening and receding sporadically because of false announcements about money that does not actually exist (to "buy time")
Suppressing Speech by Blackmail, the Iran Story
When Debian wanted to stage a seemingly legitimate election it needed to have more than one candidate running; so eventually the female partner of a geek rose to the challenge (had no coding skills at all, no technical history in Debian) and lost to the "incumbent German"
Too Focused on Buzzwords the Media is Paid to Saturate the Collective Mind With
Just because companies do really bad things in the digital realm does not imply "AI" or follow from "AI"
Discrimination and Prejudice Against Female Journalists
we can shame people who attack a reporter on the grounds of gender
An American War on GNU/Linux, Software Freedom, and British Investigative, Science-Based Reporting - Part II - Trying to Put People in Prison for Committing the Act of Journalism
This is abuse of process
Attack on Copyright and Copyleft by Code Conversion Is Nothing New, It Predates Slop (Code Produced by LLMs) by Several Decades
Even back in the 90s many people converted programs from one language to another. That could invalidate copyleft (and copyright), which already existed
Almost a Slopless Weekend for "Linux"
Let's hope slop will come to an end or sites will cease linking to slop
Insiders Explain Why IBM is Dying and the Inherent Culture Problem
There are many ways to shave this IBM cat
Links 08/03/2026: Microsoft Lost $400 Million on "Project Blackbird" and Half the States Sue Over Illegal Tariffs
Links for the day
Links 08/03/2026: Cisco Holes Again and "Blatant Problem With OpenAI That Endangers Kids"
Links for the day
Activism/Journalism in Our Blood
one must fight for one's principles
Gemini Protocol in Its Prime
What's particularly neat about Gemini Protocol is that it's fast and cheap
Microsofters' SLAPP Censorship - Part 6 Out of 200: Intentionally Misnaming Women, People Who Offered to Testify That They Too Had Been Subjected to Similar Abuse
Today it is International Women's Day
Even Fedora Leadership Cannot Figure Out the Microsoft Kill Switch/Back Door, 'Secure' Boot
It does not actually enhance security
Bruce Perens: Richard Stallman "Has Achieved His Goal"
Stallman's next talk is tomorrow
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Saturday, March 07, 2026
IRC logs for Saturday, March 07, 2026
Gemini Links 07/03/2026: Buying Woodland, Indra 1.3.0 Available, and LLM Exhaustion
Links for the day
The Harder They Attempt to Take Down This Site (and Take Away Liberties), the More People Will See This Site
We'll carry on as usual, as from sunlight comes justice
An American War on GNU/Linux, Software Freedom, and British Investigative, Science-Based Reporting - Part I - A Matter of National Security
Those people are Americans who try to advance the interests of American corporations by weaponising courts abroad
Why They Always Try to Shoot the Messenger (When the Message Harms Profits)
A matter of economics
Coinbase - Like Block - is in Huge Trouble, Its Debt Nearly Doubled in Half a Year
The real reason Block is collapsing is its debt
Starting Another New Series This Evening, It's About American Folly
today commences a series long in the making (years)
Nations Stand to Benefit From Gender Equality and Increased Participation by Women
International Women's Rights Day starts in about 6 hours in the UK
Microsoft is Losing It, Now It's Censoring Its Critics and Sceptics
Whether the measurements made by statCounter are accurate or not, the trends (long-term) typically make sense
WIRED (Conde Nast) Reviews Are Paid-for Marketing Spam, They Change Dates on Old 'Articles' to Make Them Look Relevant and New
The Web is fast becoming a burial ground for ads, trash, spam, and slop
Gemini Links 07/03/2026: Humour, Chilling, and Oversized 'Phones'
Links for the day
Cyber|Show by Andy and Helen Recommended by Techrights and Tux Machines
If your time is limited and you look for informative essays and shows (audio)
Links 07/03/2026: CJEU to Finally Examine Behaviour of the Illegal and Unconstitutional Unified Patent Kangaroo Court, Creative Commons (CC) Hosts Open Heritage Statement Event in Amsterdam
Links for the day
Microsoft's Thailand Problem
It's definitely not Windows
New Lows for Microsoft in Micronesia
GNU/Linux has shown some growth there too
Microsofters' SLAPP Censorship - Part 5 Out of 200: Clearly Not a Security Professional/Expert, Only Ever Pretending to be One
"The Claimant says he is “a computer security expert”, but his background and his track record in the education sense (genetics) does not support this assertion."
Links 07/03/2026: Fuel Already Running Low and "Economic Crisis of the Iran War"
Links for the day
The Corporate Media Repeated the Lies Told by Jack Dorsey ("AI" Hype), Now It Does the Same for Larry Ellison
Disregard the hundreds of headlines that say mass layoffs at Oracle are due to "AI" something
The Free Software Community is Gaining Momentum as Its Importance is More Broadly Realised
As long as "trendy" technology goes in a negative direction there will be a growing portion in society looking for alternatives
Spooking or Chasing Away Women (From Computer Science)
The status quo discourages women from even trying to study Computer Science and related disciplines
"IBM Has Changed So Much in the Last Decade to the Point It's Completely Unrecognizable."
IBM is a dying, rotting company with a morbid culture
The Register MS, Sponsored by Communist Party of China (CPC)
What will happen when the bubble crashes the economy?
Over at Tux Machines...
GNU/Linux news for the past day
IRC Proceedings: Friday, March 06, 2026
IRC logs for Friday, March 06, 2026
Gemini Links 07/03/2026: Coffee Problem, Marchintosh, Learning, and "Selectively Disabling HTTP"
Links for the day