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The Tower Group expected that the customer-centric module of SBS
would become the "core foundation around which a bank can integrate
all of its customer information".
The development of the deposit and credit modules, however,
does not constitute qualified research. The record is void of any
testimony or evidence (other than reports dated after 1991, after
the timeframe in issue) from which we can evaluate the nature of
the work performed on the deposit and credit modules. We note
however Mr. Teixeira's indication that the deposit and credit
modules provided "no significant functional innovations to the
industry".
The SBS customer module project involved the discovery of
information which was technological in nature and expanded
principles of computer science--namely, the ability to create a
customer-based system that could integrate with other banking
systems and handle large volumes of data. In this regard, we note
that qualified research for purposes of section 41 is not limited
to the development of new technology but also encompasses the use
of existing technology in new and dynamic ways.
There is no doubt that SBS provided a new or improved business
component of Norwest in terms of customer service and growth
opportunities. The Tower Group described the GMAC customer module
system as providing "quicker, more efficient underwriting, and a
faster, accurate understanding of changes in automobile purchase
behavior". The sheer volume capacity of SBS, as compared with the
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