In Uniloc USA, Inc. v. Rackspace Hosting, Inc., Case No. 6:12-CV-375 (E.D. Tex. Mar. 27, 2013), the district court granted Rackspace’s motion to dismiss, holding that the patent-in-suit was invalid for claiming unpatentable subject matter under 35 U.S.C. § 101. The asserted claim of the patent-in-suit purports to optimize the processing of floating point numbers by a computer by rounding the number before performing an arithmetic operation, in contrast to a broadly implemented IEEE standard under, which the result is rounded after the completion of the arithmetic operation. The district court first determined that the claimed process failed both prongs of the machine-or-transformation test, as the claim recites no machine whatsoever, and because mere manipulation of data does not satisfy the transformation prong. Because the machine-or-transformation test is not itself determinative of patent eligibility, the district court then turned to the three exceptions to § 101’s patent-eligibility principles: laws of nature, physical phenomena, and abstract ideas. The district court held that the claimed process was unpatentable under § 101 as a mathematical formula, even if it did not describe a particular arithmetic operation. The district court further held that even if the claimed process is an improvement over an existing industry standard, it is still merely an improvement on a mathematical formula, and such a patent would cover vast end uses, impeding the onward march of science.