""Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent ….” - 35 U.S.C. § 101. The above excerpt of § 101 is the basis of patent law in the U.S. With the exception of a small modification in 1952, § 101 has remained virtually unchanged since written by Thomas Jefferson. Until recent times, the statute gathered little attention. However, with the addition of software and business method patents in the 1980’s, the statute has been the subject of dispute."