In re Chatfield

Citation: In re Chatfield, 545 F.2d 152, 191 U.S.P.Q. (BNA) 730 (C.C.P.A. 1976), cert. denied, 434 U.S. 875, 195 U.S.P.Q. (BNA) 465 (1977).

Claims to an invention which evaluated and reassigned program priorities as programs executed in a multi-program computing system, although drawn to a method of operating a computing system, simply defined a novel method for operating that particular machine system in a particular mode and were not drawn to a mathematical problem-solving algorithm or to purely mental steps. The claims therefore defined patentable subject matter.

Wile the method adjusted priorities of computer processing programs, no program per se was claimed. The court narrowly construed the U.S. Supreme Court’s holding in Gottschalk v. Benson to apply only to claims which "would have preempted all practical uses of both the underlying mathematical formula and the involved algorithm." It refused to construe Gottschalk v. Benson as holding all computer programs unpatentable.