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101 -- provided that the patent claims are directed to markedly different characteristics from any found in nature and have the potential for significant utility. Interestingly, the Federal Circuit relied heavily on the older Chakrabarty case (bacteria transfected with 4 genetically engineered plasmids allowing them to degrade oil contamination, something no naturally occurring bacteria could do) and mentioned the newer Alice/Mayo cases almost as an afterthought, probably because the facts of Chakrabarty were so similar to the facts of this case

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