Parker v. Flook - 437 U.S. 584, 98 S. Ct. 2522 (1978)

Rule:

The discovery of a novel and useful mathematical formula may not be patented.

Facts:

Respondent applied for a patent on an alarm system relating to the catalytic converter process. The patent examiner rejected the application, finding that the mathematical formula constituted the only difference between respondent's claims and the prior art. The examiner concluded that the claims did not describe a discovery that was eligible for patent protection. Petitioner, the Acting Commissioner of Patents and Trademarks, sustained the examiner's rejection, likewise concluding that the point of novelty in respondent's claimed method lay in the formula or algorithm described in the claims, a subject matter that was not patentable. The lower court reversed. Petitioner sought review of the decision. 

Issue:

Was the respondent’s “alarm limit” eligible for patent protection?  

Answer:

No.

Conclusion:

The Court reversed the judgment of the lower court, holding that the method for updating alarm limits was not patentable under 101 of the Patent Act. According to the Court, the identification of a limited category of useful, though conventional, post-solution applications of the formula not making the method eligible for patent protection.