He found that the Federal Circuit held more than 90 percent invalid, while district courts invalidated more than 70 percent. In one of these district court decisions, Federal Circuit Judge Bryson, sitting by designation as a district judge, spoke of these business method patents as uninventive and mere "aspirational" recitations of "methods for performing a commonplace business function" without any description of "any novel manner of performing that function" other than saying "do it with a computer": In short, such patents, although frequently dressed up in the argot of invention, simply describe a problem, announce purely functional steps that purport to solve the problem, and recite standard computer operations to perform some of those steps. The principal flaw in these patents is that they do not contain an "inventive concept" that solves practical problems and ensures that the patent is directed to something "significantly more than" the ineligible abstract idea itself. As such, they represent little more than functional descriptions of objectives, rather than inventive solutions. In addition, because they describe the claimed methods in functional terms, they preempt any subsequent specific solutions to the problem at issue. See also Business method patent Diamond v. Diehr Ex Parte Lundgren Freeman-Walter-Abele Test Diamond v. Chakrabarty In re Bilski Bilski v. Kappos References External links "We've Got Algorithm--Software Patents Boom" Commentary on Cornell University web site "After The Gold Rush" Software patent case law United States Court of Appeals for the Federal Circuit cases United States patent case law 1998 in United States case law