transformation is sufficient to impart patent-eligibility under ยง 101. It is virtually self-
evident that a process for a chemical or physical transformation of physical objects or
substances is patent-eligible subject matter. As the Supreme Court stated in Benson:
[T]he arts of tanning, dyeing, making waterproof cloth, vulcanizing India
rubber, smelting ores . . . are instances, however, where the use of
chemical substances or physical acts, such as temperature control,
changes articles or materials. The chemical process or the physical acts
which transform the raw material are, however, sufficiently definite to
confine the patent monopoly within rather definite bounds.
409 U.S. at 70 (quoting Corning v. Burden, 56 U.S. (15 How.) 252, 267-68 (1854)); see
also Diehr, 450 U.S. at 184 (process of curing rubber); Tilghman, 102 U.S. at 729
(process of reducing fats into constituent acids and glycerine).
The raw materials of many information-age processes, however, are electronic
signals and electronically-manipulated data. And some so-called business methods,
such as that claimed in the present case, involve the manipulation of even more
abstract constructs such as legal obligations, organizational relationships, and business
risks. Which, if any, of these processes qualify as a transformation or reduction of an
article into a different state or thing constituting patent-eligible subject matter?
Our case law has taken a measured approach to this question, and we see no
reason here to expand the boundaries of what constitutes patent-eligible
transformations of articles.
Our predecessor court's mixed result in Abele illustrates this point. There, we
held unpatentable a broad independent claim reciting a process of graphically
displaying variances of data from average values. Abele, 684 F.2d at 909. That claim
did not specify any particular type or nature of data; nor did it specify how or from where
the data was obtained or what the data represented. Id.; see also In re Meyer, 688 F.2d
2007-1130 25