I just finished reading Burning the Ships: Intellectual Property and the Transformation of Microsoft by Marshall Phelps, which is a fascinating account of the transformation of Microsoft's patent power during Marshall Phelp's tenure there. Under his leadership, Microsoft has become a significant holder of patents covering many important aspects of Microsoft's technology. The book is well worth the read for anyone who wants to understand Microsoft's patent strategy.
On March 27, Judge Patel in the Norther District of California extended the reach of Bilski well beyond the dicta in that case. In Cybersource v. Retail Decisions (California Civil Case No. 3:04-cv-03268-MHP), Judge Patel ruled that "[a] method for verifying the validity of a credit card transaction over the Internet" that obtains "information about ... transactions that have utiliized an Internet address" does not satisfy the method-or-transformation test promulgated by Bilski. She also ruled that Beauregard claims also must satisfy the machine-or-transformation test independent of reciting the storage of computer-executable instructions on a computer-readable storage medium.
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