The Federal Circuit overturned a patent invalidity finding, citing the Bilksi judgment, in a case between Research Corporation Technologies and Microsoft concerning process patents. In the opinion, Rader said that the Supreme Court in Bilski said the Section 101 patent-eligibility inquiry "is only a threshold test". Noting that the Court had rejected the Federal Circuit's machine-or-transformation test, he said: "[S]ection 101 does not permit a court to reject subject matter categorically because it finds that a claim is not worthy of a patent." For processes, said Rader, the Supreme Court "refocused" the inquiry on the question of whether the subject matter is abstract - but did not provide a rigid formula or definition for abstractness. He went on to conclude that because the inventions in the patents are directed to patent-eligible subject matter, "the process claims at issue, which claim aspects and applications of the same subject matter, are also patent-eligible".
