State Street Bank & Trust Co. v. Signature Financial Group, Inc.
| State Street Bank & Trust Co. v. Signature Financial Group, Inc. | |
|---|---|
| Court | United States Court of Appeals for the Federal Circuit |
| Full case name | STATE STREET BANK & TRUST CO., Plaintiff-Appellee, v. SIGNATURE FINANCIAL GROUP, INC., Defendant-Appellant |
| Decided | July 23 1998 |
| Citation | 149 F.3d 1368 |
| Case history | |
| Prior history | Finding for plaintiff, 927 F. Supp. 502, 38 U.S.P.Q.2d 1530 (D. Mass. 1996) (finding U.S. Patent No. 5,193,056 invalid for lack of statutory subject matter) |
| Holding | |
| A claim is eligible for protection by a patent in the United States if it involved some practical application and it produces a useful, concrete and tangible result. | |
| Court membership | |
| Judges sitting | Circuit Judges Rich, Plager and Bryson |
| Case opinions | |
| Majority | Rich |
| Laws applied | |
| 35 U.S.C. § 101 | |
State Street Bank and Trust Company v. Signature Financial Group, Inc., 149 F.3d 1368 (Fed. Cir. 1998), also referred to as State Street or State Street Bank, was a 1998 decision of the United States Court of Appeals for the Federal Circuit concerning the patentability of business methods. State Street for a time established the principle that a claimed invention was eligible for protection by a patent in the United States if it involved some practical application and, in the words of the State Street opinion, "it produces a useful, concrete and tangible result."
With the 2008 Federal Circuit decision In re Bilski, however, the useful-concrete-tangible test was jettisoned. According to the Federal Circuit's Bilski opinion, the "'useful, concrete and tangible result inquiry' is inadequate," and the portions of the State Street decision relying on this inquiry are no longer of any effect under US patent law. The Supreme Court affirmed the judgment of the Federal Circuit in Bilski v. Kappos.