Cloud atlas was published in 1802. It followed a similar effort in French by Jean-Baptiste Lamarck in 1801. Howard's nomenclature defined four fundamental types of clouds: cirrus or thread-cloud, cumulus or heap-cloud, stratus or flat cloud (level sheet), and nimbus or rain-cloud (see Classification of clouds). There followed a long period of development of the field of meteorology and the classification of clouds, leading up to 1896, the International Year of Clouds. The history of this period is the subject of a popular book, "The Invention of Clouds". During that time, the Englishmen Rev. Clement Ley and Hon. Ralph Abercromby, were influential.
Machine-or-transformation test generally insufficient to make an otherwise ineligible method claim patent-eligible. The PTO Guidance Memo explains that "[t]his means the machine or transformation must impose meaningful limits on the method claim's scope [for it] to pass the test." What makes a limitation meaningful is unstated, but perhaps that concept can be defined in terms of whether the limitation places only an insubstantial limitation on claim scope or preemptiveness. The second corollary is that insignificant extra-solution activity will not transform a patent ineligible principle into a patentable process. The PTO Guidance Memo explains that "[t]his means reciting a specific machine or a