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In Bilski v. Kappos, the Supreme Court rejected calls to categorically exclude business methods-or any technology-from the scope of patent law. 1 It also rejected as the sole test of subject matter eligibility the Federal Circuit's deeply-flawed machine-or-transformation test, under which no process, and perhaps no invention of any type, is patentable unless it is tied to a particular machine or transforms an article to another state or thing. 2 Nonetheless, the Court held that the machine-or-transformation test still" is a useful and impor-tant clue, an investigative tool, for determining whether some claimed inventions" are patentable subject matter. 3 The result was a (narrow) victory for inventors, as well as for context-specific standards over formal rules.