Ex Parte HECKERMAN et al - Page 5



          Appeal No. 1999-2314                                                        
          Application 08/739,200                                                      

          the improvements found in manipulating its overall structure.               
          The examiner responds that the claimed invention is not limited             
          to a practical application because the whole world can be                   
          encompassed by the claim.  The examiner also responds that the              
          claimed invention, as a product of manufacture, is not patentable           
          because the claims encompass any and every computer-readable                
          memory product implemented on any and every type of general                 
          purpose computer, configured in any manner to perform the process           
          [answer, pages 5-15].                                                       
          Appellants respond that the claimed invention is                            
          statutory because it uses empirical data which results from                 
          measurements of tangible, concrete and physical things, not mere            
          abstract ideas.  Appellants also respond that even though the               
          claimed invention may have many practical applications, that fact           
          does not make the invention an abstract idea.  Appellants also              
          respond that computer programs embodied on a tangible medium are            
          patentable subject matter.  Finally, appellants argue that a                
          belief network is similar to a neural network which has been                
          indicated as being patentable in the guidelines noted above                 
          [reply brief].                                                              



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