the exception for abstract ideas “is more of a problem, a problem inherent in the search for a definition of an ‘abstract idea’ that is not itself abstract”). Some guiding principles, however, have emerged from Supreme Court and Federal Circuit precedent. The courts have determined that mathematical formulas and algorithms, as well as fundamental economic principles, are abstract ideas. See Alice, 134 S.Ct. at 2356 (finding the concept of intermediated settlement, or “exchanging financial obligations between two parties using a third-party intermediary to mitigate settlement risk,” to be an abstract idea); Bilski v. Kappos, 561 U.S. 593, 611—12, 130 S.Ct. 3218, 177 L.Ed.2d 792 (2010) (finding the concept of risk hedging to be an abstract idea); Benson, 409 U.S. at 71-72, 93 S.Ct. 253 (<HOLDING>); OIP Techs., Inc. v. Amazon.com, Inc., 788
holding an issue must be raised to and ruled upon by the trial court in order to be preserved for review holding that a mathematical algorithm must produce a useful concrete and tangible result to be patentable holding that statements made in a letter to the editor regarding a psychologists behavior modification techniques were not pure opinion because the letter might reasonably be understood to imply the assertion of undisclosed facts holding an algorithm for converting binarycoded decimal numerals to pure binary numerals to be patentineligible holding an issue must be raised to and ruled upon by the trial court to be preserved for appellate review