[3] In Lincoln Engineering, the inventor invented a new and improved coupling device to attach a nozzle to a grease gun.
[7] In effect, the Federal Circuit overruled the Supreme Court on this point—or claimed that the passage of the 1952 patent recodification law had done so.
Again, by providing a mechanical environment, even though it was an exhausted combination, the claims drafter might have avoided the holding of nonstatutory subject matter.
It is possible that careful claims drafting techniques will succeed in elevating form over substance, to avoid the impact of the machine-or-transformation test.
The form of analysis that these cases dictate is that the presence of a machine, in particular a programmed digital computer, is not enough without more to assure patent eligibility.
The inventive concept must provide "something extra" that extends beyond the algorithm or other idea, if an otherwise patent-ineligible claim is to be saved from patent ineligibility—according to these cases and recent lower court decisions that follow in their wake.