Today, we hold that the transformation of data, representing discrete dollar amounts, by a machine through a series of mathematical calculations into a final share price, constitutes a practical application of a mathematical algorithm, formula, or calculation because it produces “a useful, concrete and tangible result”—a final share price momentarily fixed for recording and reporting purposes and even accepted and relied upon by regulatory authorities and in subsequent trades. (Emphasis added).
Whether the patent's claims are too broad to be patentable is not to be judged under § 101, but rather under §§ 102, 103 and 112. Assuming the above statement to be correct, it has nothing to do with whether what is claimed is statutory subject matter.
The State Street claims were directed to machines, although in dicta, the Federal Circuit indicated that for patentability purposes, it did not matter whether the claim was directed to a machine or a process. Still, some uncertainty remained as to whether the Federal Circuit would actually apply the same analysis to a § 101 challenge of a process patent.
AT&T Corp. v. Excel Communications, Inc., 172 F.3d 1352 (Fed. Cir. 1999)
The State Street and AT&T decisions opened the door to providing patent protection for methods of doing business on the Internet, as long as they have a “useful, concrete, and tangible result.”