Patent claiming "a business method for creating an investment instrument out of real property" that "ensures that the invented investment instrument was eligible for tax-deferred treatment under Section 1031 of the Internal Revenue Code" did not "transform any article to a different state or thing" as required under In re Bilski, 545 F.3d 943 (Fed. Cir. 2008). "Like the claims at issue in Bilski, the claims of the [patent-in-suit] involve only the transformation or manipulation of legal obligations and relationships. Specifically, the claims of the [patent-in-suit] only transform or manipulate legal ownership interests in real estate. Under Bilski, the Court cannot find that those claims transform an article or thing."
Fort Properties Inc v. American Master Lease LLC, 8-07-cv-00365 (CACD January 22, 2009, Order)