United States Court of Appeals for the Federal Circuit, 8 December 2010, Opinion No. 2010-1037 in Research Corporation Technologies, Inc., Plaintiff-Appellant, v. Microsoft Corporation, Defendant-Appellee.
A “process” for rendering a halftone image qualifies under both the categorical language of 35 U.S.C. § 101 and 100 (b) and does not disqualify as an abstract idea. The section 101 patent-eligibility inquiry is only a threshold test and no substitute for a patentability analysis related to prior art, adequate disclosure, or the other conditions and requirements of Title 35. While no definition of "abstract" is given, it is recognised that this disqualifying characteristic should exhibit itself so manifestly as to override the broad statutory categories of eligible subject matter and the statutory context that directs primary attention on the patentability criteria of the rest of the Patent Act.