The court denied defendants' motion for summary judgment that plaintiff's patented method for computing medical codes was invalid for claiming unpatentable subject matter. The claims did not satisfy the machine-or transformation test because they (i) "require[d] the use of a general purpose computer for computation, storage, and display [and] these generic functions do not impose meaningful limits on the claims," (the machine prong) and (ii) they "involve[d] . . . manipulating data gathered in a physician–patient encounter and generating a final CPT code [which does not involve] . . . physical and tangible objects" (the transformation prong). Nevertheless, the claims were not invalid because they were not "drawn to an abstract idea." "The [patent-in-suit's] claims are not drawn to an abstract idea. They involve the use of a computer and complex programming and are not drawn to purely mental processes. Prior attempts to solve the coding problems addressed by the [patent] entailed hiring full-time coders who pored over medical records and tomes of information about CPT code criteria to determine the appropriate code. The [patent] claims provide a patentable improvement to the previous methods for determining the CPT codes for a physician–patient encounter. The claims are also subject to meaningful limits. They relate specifically to a physician–patient encounter and involve the determination of a specific type of medical procedure code that is published by the AMA."
Prompt Medical Systems, L.P. v. AllscriptsMisys Healthcare Solutions, Inc., et. al., 6-10-cv-00071 (TXED February 13, 2012, Order) (Davis, J.)