business. The rationales for those decisions sometimes varied. But there was an overarching theme, at least in dicta: Business methods are not patentable arts. See, e.g., United States Credit System Co. v. American Credit Indemnity Co., 53 F. 818, 819 (CCNY 1893) (“method of insuring against loss by bad debts” could not be patented “as an art”); Hotel Security Checking Co. v. Lorraine Co., 160 F. 467, 469 (CA2 1908) (“A system of transacting business disconnected from the means for carrying out the system is not, within the most liberal interpretation of the term, an art”); Guthrie v. Curlett, 10 F.2d 725, 726 (CA2 1926) (method of abbreviating rail tariff schedules, “if it be novel, is not the kind of art protected by the patent acts”); In re Patton, 127 F.2d 324, 327-328 (CCPA 1942) (<HOLDING>); Loew’s Drive-In Theatres, Inc. v. Park-In
holding that novel  interstate and national firefighting system  was not patentable because inter alia a system of transacting business apart from the means for carrying out such system is not an art within the meaning of the patent law nor is an abstract idea or theory regardless of its importance or    ingenuity holding that a state is not a person within the meaning of  1983 holding kansas public employees retirement system is not as a state agency considered a person for purposes of  1983 liability holding that a consent to search is not an interrogation within the meaning of miranda  holding that in the context of hobbs act prosecutions  an indictment need not set forth facts alleging how interstate commerce was affected nor otherwise state any theory of interstate impact