In re Meyer, 1982

Meyer’s invention related to a system for aiding a neurologist in diagnosing patients. Meyer’s claims were directed to a method of storing and correlating test responses on a complex system.

The CCPA upheld the Board of Patent Appeals and Interferences’ affirmance of an Examiner’s rejection of Meyer’s claims as being unstatutory under 35 USC § 101.

The court applied the first part of the two-part Freeman-Walter test to the Meyer claims, relying on the applicants’ specification and arguments, and found that the invention was concerned with partly replacing the thinking processes of a neurologist with a computer. The court then concluded that a mathematical algorithm was involved in the claims.

With respect to the second part of the Freeman-Walter test, the Court stated that Walter had modified Freeman to require an inquiry into whether the algorithm is implemented in a specific manner to define steps in process claims. The court stated that Walter was not intended to be an exclusive test, but that a more comprehensive test is to be found in Abele.

The Court state that the question should be whether the mental process is applied to physical elements or process steps in an otherwise statutory process, machine, manufacture, or composition of matter.

Applying this analysis to the Meyer claims, the Court found that the algorithm of the applicants’ claims had not been applied to physical elements or process steps and were not to an otherwise statutory process or apparatus.