Gottschalk v. Benson
Headline: Court rejects patenting of a computer algorithm that converts decimal-coded numbers into pure binary, blocking broad patents on general-purpose computer programs and preventing a monopoly over a mathematical formula.
Holding:
- Prevents broad patents that would monopolize mathematical algorithms for computer programs.
- Keeps conversion algorithms usable without a patent monopoly on general-purpose computers.
- Signals Congress to consider new rules for patenting computer programs.
Summary
Background
Respondents applied to the Patent Office for an invention described as relating to "the processing of data by program" and to converting binary-coded decimal (BCD) numerals into pure binary. The claims were not limited to any particular machine, technology, or end use, and they would cover using the method in any general-purpose digital computer. The Patent Office rejected claims 8 and 13, but the Court of Customs and Patent Appeals sustained them, and the case reached this Court to decide whether the claimed method is a "process" under the Patent Act.
Reasoning
The Court explained what a digital computer is and described the claimed steps as an algorithm — a mathematical procedure for converting one numeral form to another. Citing long-standing precedent, the Court said scientific truths, mathematical expressions, and abstract ideas are not patentable. Because the claim would pre-empt the mathematical formula and cover all uses on digital computers, the Court concluded it was too abstract and sweeping to be a patentable process. The Court noted it was dealing only with programs for digital computers and did not categorically rule out all process patents unrelated to machines. The opinion also said that if programs should be patentable, Congress must make that change.
Real world impact
As a result, the decision prevents granting a patent that would effectively monopolize this conversion algorithm and similar mathematical procedures when used on general-purpose digital computers. The Court reversed the lower court and left policy questions about patenting computer programs to Congress and to any future legislative action recommended by expert commissions.
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