In Re Board of Trustees of the Leland Stanford Junior University, No. 20-1012 (Fed. Cir. 2021)Annotate this Case
Stanford’s 925 application is directed to methods and computing systems for determining haplotype phase--an indication of the parent from whom a gene has been inherited. Improved haplotype phasing techniques “promise to revolutionize personalized health care by tailoring risk modification, medications, and health surveillance to patients’ individual genetic backgrounds.” Achieving the understanding necessary to accomplish those goals requires “interpretation of massive amounts of genetic data produced with each genome sequence.” The 925 application describes a method for receiving genotype and pedigree data and processing the data by performing mathematical calculations and statistical modeling to arrive at a haplotype phase determination.
The Federal Circuit affirmed the Patent Trial and Appeal Board in rejecting the claims as patent-ineligible under 35 U.S.C. 101 because they are drawn to abstract mathematical calculations and statistical modeling, and similar subject matter that is not patent-eligible. Claim 1 recites no steps that practically apply the claimed mathematical algorithm; instead, claim 1 ends at storing the haplotype phase and “providing” it “in response to a request.” Simply storing information and providing it upon request does not alone transform the abstract idea into patent-eligible subject matter.