Section 101 of U.S. patent law (35 U.S.C. §101) provides that: Process, machine, manufacture, composition of matter and new and useful improvements constitute the categories of patentable subject matter. The latter three categories define "things" or "products" while the first category defines "actions" (i.e., inventions that consist of a series of steps or acts to be performed). Section 101 defines in “expansive terms” the categories of patent-eligible inventions. Thomas Jefferson, an author of the Act of Feb. 21, 1793 (1793 Patent Act), desired that “ingenuity should receive a liberal encouragement,” and broad and flexible patent laws are integral to that goal. Consistent with that intent, “[t]he subject-matter provisions of the patent law have been cast in broad terms to fulfill the con