One of the issues that United States Patent and Trademark Office reviews in a patent application is the subject matter of the invention. A patent application must also describe an invention which may be patented. Section 101 of Title 35 of the United States Code defines the subject matter that may be patented under the Patent Act. Under § 101, the scope of patentable subject matter encompasses any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof. Patents cannot be granted on laws of nature, natural phenomena, and abstract ideas. If a patent application describes an invention which is not patentable, the United States Patent and Trademark Office will deny the patent application.