1994) was a 1994 decision of the United States Court of Appeals for the Federal Circuit on the patent eligibility of data structures.

An ADO is a single primitive data element "compris[ing] sequences of bits which are stored in the memory as electrical (or magnetic) signals that represent information.

Lowry asserted that using ADOs provided a more efficient method for storing, retrieving, adding, and removing information from a database.

The court held, per Judge Rader, that all of Lowry's software data structure claims were patentable.

"[5] The court also maintained that Lowry's claimed data structure did sufficiently interact with the substrate (the computer memory) to satisfy the functional relationship standard.

[8] The court stated: "The PTO did not establish that the ADOs, within the context of the entire claims, lack a new and nonobvious functional relationship with the memory."

Under prevailing Federal Circuit patent law doctrine, the court noted, it was the burden of the PTO to prove that this relationship was obvious.

The Federal Circuit began to abandon the policy reflected in such cases as In re Schrader,[10] which emphasized the importance of hardware elements to provide patent eligibility for software,[11] and developed its own standards for patent eligibility that were different from those of Supreme Court precedents.

In a series of cases from Gottschalk v. Benson and Parker v. Flook in the early 1970s to Diamond v. Diehr in the early 1980s, the Department of Justice had supported the Patent Office and PTO's appeals from judicial decisions overturning the agency's rejections of computer software patents.

"[13] In addition, personnel changes at the Justice Department and PTO occurred that lessened support for such appeals.

Under the legal analysis now prescribed in the Alice case, the ADO of claim 1 in Lowry today probably would be held a patent-ineligible abstract idea.