California Court Doesn't Like Software Patents
On March 27, Judge Patel in the Northern 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.