[** ] Mr. Sachs holds a B.A. in philosophy and B.A. in psychology from the University of San Diego and a J.D. from Yale Law School. He is presently working on an M.S. in Software Engineering. The following position paper is submitted as Mr. Sachs' personal opinion based on his understanding of patent case law, his experience with software technologies, and his experience in prosecuting software patent applications. The views expressed are his own and do not represent the opinions or positions of any institution with which he is affiliated.

[1] 60 Fed. Reg. 28,778 at 28,780 (proposed June 2, 1995).

[2] Id.

[3] Id.

[4] Id. at 28,779.

[5] Diamond v. Chakrabarty, 447 U.S. 303, 309 (1980).

[6] 33 F.3d 1526, 1545 (Fed. Cir. 1994).