mathematical formula, even if the solution is for a specific purpose, the claimed method is nonstatutory [patent ineligible].' " Furthermore, in July 2014, just after the Alice decision came down, a Federal Circuit panel held a patent ineligible, quoting Flook and adding: "Without additional limitations, a process that employs mathematical algorithms to manipulate existing information to generate additional information is not patent eligible." Judge Bryson's comments, quoted above, may therefore be more predictive of the likely outcomes of future software-related patent cases, including encryption ones, than counsel's assurances during oral argument in the Alice case. Allvoice In Allvoice Developments US, LLC v. Microsoft Corp., the Federal Circuit in a May 2015 nonprecedential opinion invalidated patent claims to a speech recognition "interface" without undertaking an Alice analysis. The so-called interface was entirely a set of software instructions, claimed in means-plus-function form. The court found it unnecessary to go through the two-step analysis because a set of instructions is not a machine or article of manufacture or composition of matter, and it did not purport to be a process. Accordingly, the claimed subject matter did not fit within any of the statutory categories of section 101, which defines patentable subject matter. Moreover, it was intangible, and in the Digitech case, the Federal Circuit had held that except for processes, "eligible subject matter must exist in some physical or tangible form." Landmark decisions Gottschalk v. Benson Parker v. Flook Diamond v. Diehr State Street Bank v. Signature Financial Group In re Bilski Alice Corp. v. CLS Bank International DDR Holdings v. Hotels.com See also Machine-or-transformation test Software patent Software patent debate Software patents under the European Patent Convention Software patents under TRIPs Agreement Limitations on exclusive rights: Computer programs (United States copyright law) References Further reading Ben Klemens, Math You Can't Use: Patents, Copyright, and Software. Brookings Institution Press, 2005. Manual of Patent Examining Procedure, Chapter 2100 United States patent law United States patent law