certain cases under the correct test to glean greater guidance as to how to perform the
§ 101 analysis using the machine-or-transformation test.
The machine-or-transformation test is a two-branched inquiry; an applicant may
show that a process claim satisfies § 101 either by showing that his claim is tied to a
particular machine, or by showing that his claim transforms an article. See Benson, 409
U.S. at 70. Certain considerations are applicable to analysis under either branch. First,
as illustrated by Benson and discussed below, the use of a specific machine or
transformation of an article must impose meaningful limits on the claim's scope to impart
patent-eligibility. See Benson, 409 U.S. at 71-72. Second, the involvement of the
machine or transformation in the claimed process must not merely be insignificant extra-
solution activity. See Flook, 437 U.S. at 590.
As to machine implementation, Applicants themselves admit that the language of
claim 1 does not limit any process step to any specific machine or apparatus. See
Appellants' Br. at 11. As a result, issues specific to the machine implementation part of
the test are not before us today. We leave to future cases the elaboration of the precise
contours of machine implementation, as well as the answers to particular questions,
such as whether or when recitation of a computer suffices to tie a process claim to a
particular machine.
We will, however, consider some of our past cases to gain insight into the
transformation part of the test. A claimed process is patent-eligible if it transforms an
article into a different state or thing. This transformation must be central to the purpose
of the claimed process. But the main aspect of the transformation test that requires
clarification here is what sorts of things constitute "articles" such that their
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