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Patent Textualism
Get PDFThe Supreme Court today embraces textualism—the practice of interpreting legal text by reference to how an ordinary person would have understood that text at the time it was promulgated. Yet, when it comes to patent cases at the Court interpreting the statutory provision governing patent eligibility, textualism has rarely been used as an interpretive tool. This Article, besides highlighting this contradiction, will consider how textualism’s application to this foundational aspect of the patent statute would change patent law.
This Article will analyze the Supreme Court’s adoption of textualist principles in other fields and then evaluates the application of textualism to the field of patent law. In particular, this Article will consider the extent to which the Supreme Court has interpreted the patent statute consistent with the tenets of textualism. There is surprisingly little prior analysis of textualism applied to the patent statute—no one else has systematically analyzed the Court’s use of textualism in the patent field. Thus, this Article will be the first to identify the Court’s failure to apply textualism consistently to the patent statute.
The most notable exception to the Court’s general practice of using textualism to interpret the patent statute relates to the statutory provision governing patent eligibility. Because this provision defines the types of inventions that are and are not eligible for patenting, it serves as the gateway to the patent system. It is the foundation for the whole patent system. Despite its importance, this Article’s analysis will show the Court has interpreted this provision using interpretive tools the Court has generally rejected in other fields to reach interpretations of the patent statute that are inconsistent with textualism.
This Article will conclude by highlighting how a textualist approach to interpreting the statutory provision governing patent eligibility would broaden eligibility. In other words, a textualist approach will expand the scope of which types of inventions are eligible for patenting. More importantly—regardless of whether one views expanded eligibility as an advance—textualism would return political power over the doctrine of patent eligibility to the political branches of our government, while also providing needed clarity over the question of what is and is not eligible for patenting
Using Generative AI to Procedurally Populate Assets in an ASCII Level
Get PDFThis study focuses on how to make use of generative AI in game level development by procedurally populating assets at a code-based level in a video game. The researcher aims to enhance developers’ efficiency in aesthetic milestone by adapting a pipeline in which generative AI handles decoration process that has less impact on gameplay. Consequently, the researcher creates a pipeline outlining the best practices for conducting the pipeline using generative AI. The researcher constructed a game level in Left 4 Dead 2 to explore the effectiveness of this pipeline. Testers play the level and provided feedback regarding their experiences, especially on decoration quality. The researcher analyzed this data to confirm or deny whether the pipeline enhances efficiency and at the same time maintains the decoration quality of an average human-designed level
Computational Identification Of Infiltrating T Lymphocytes Into Solid Tumor
Get PDFT cells play a central role in cancer immunity. Successful anti-tumor immunotherapy relies on the effective infiltration of cytotoxic T cells. However, the tumor microenvironment presents physical and immunosuppressive barriers to prevent T cell entry. Here, we developed two novel computational tools, ReMITT and SIBERT, to search for migrating T cells and T cell entry regions (TERs) into the tumor core. SIBERT combines a novel change point detection method and a spatial imputation model to detect regions with signatures of recent T cell entry using the spatial transcriptomics data. Applying SIBERT to multiple human cancer samples revealed several TERs for each sample, which were dominantly distributed near the tumor margins rich in blood vessels. Unbiased gene expression analysis revealed key pathways and cytokine/receptors involved in T cell transmigration. Under the rationale of immunoediting, we also predicted potentially novel tumor antigens excluded from the TERs. This work provided insights in T cell exclusion for future immunotherapy developmen
Molecular Quantum Particle Algorithm (MQPA): Hybrid Quantum-Classical Learning for Molecular Property Prediction
Get PDFClassical machine learning models and quantum kernel methods often struggle to capture quantum-coherent molecular features under the constraints of noisy intermediate-scale quantum (NISQ) hardware, limiting both predictive accuracy and scalability.
This paper introduces the Molecular Quantum Particle Algorithm (MQPA), a hybrid quantum–classical framework designed to achieve chemically accurate property prediction by integrating handcrafted molecular descriptors with parameterized quantum circuits. Molecular inputs, expressed as SMILES strings, are processed via RDKit and encoded through angle-based quantum gates with entangling layers in Qiskit [1]. Quantum parameters are optimized using simultaneous perturbation stochastic approximation (SPSA) [2], while classical regression layers leverage Adam [3] with Low-Rank Adaptation (LoRA) fine-tuning [4].
Across 38 systematically varied subsets of the QM9 benchmark [5,6], MQPA achieves a mean absolute error (MAE) of 0.03 kcal/mol, outperforming both deep learning and quantum kernel baselines by 41% and surpassing the chemical accuracy threshold of 0.1 kcal/mol [7–9]. Extensive cross-platform benchmarking—including IBM Quantum, Qiskit Aer, and NVIDIA H100 clusters—demonstrates strong reproducibility, with inter-backend MAE variance below 3%.
Positioned as a scalable and hardware-aware solution, MQPA offers practical advantages for quantum-enhanced molecular property prediction across applications in quantum chemistry, drug discovery, materials design, and environmental modeling
Airplane!: Does the Federal Aviation Act Preempt State Law Design Defect Claims?
Get PDFWhich level of government—state or federal—has jurisdiction to set safety standards for aviation defect design is a nuanced issue. Generally speaking, federal law preempts state law in this context by occupying the field through a regulatory scheme that permeates aviation safety. The Federal Aviation Act of 1958 (FAAct) confers its namesake agency—the Federal Aviation Administration (FAA)—the powers to prescribe the “minimum standards required in the interest of safety.” The word “minimum” has been seized upon by those on the state side of the debate to advocate that it means the floor. And they contend that those in the Union have the freedom to set so-called higher standards—the ceiling. Granted, this may be a persuasive argument in some cases, but not here. First, the FAA has a five-stage type certification process. Further, there is a production certificate and airworthiness certificate. Second, the United States has executed treaties with foreign nations over reciprocity regarding aircraft safety standards.
Airplane accident cases are emotionally charged due to their propensity to involve fatalities—the argumentum ad passiones (appeal to emotion) fallacy. This emotional response is papering over underlying issues. If an airplane has obtained certification and tragedy strikes, there may be other avenues to explore. Negligence and tort claims come to mind. Preemption of design defect claims is limited to that context. A broader holding could sweep up remedies at law that should remain available.
As of the writing of this Article, impossibility preemption is premature but looms large. If all fifty states are permitted to enact aviation safety design laws, compliance would become problematic because air travel transcends state boundaries. Additionally, conflict preemption could arise. Divergence in design defects may place plaintiffs in the position of “heads I win, tails you lose.” Adhering to the standards for one state may fall below the threshold for another, or their frameworks may be at odds. Not to mention federal requirements
The Implications of Resale Channels in the Apparel Industry
No full textThere is widespread perception that resale platforms that allow consumers to buy and sell used apparel play an important role in reducing production and waste. Many consumers possess clothes that they rarely use because their individual utility has eroded, due to changes in fit or personal tastes. Nearly all existing resale channels, both those operated by branded apparel manufacturers and those that operate independently, promote themselves as helping to get clothes out of closets or landfills by finding new homes for them. While resale channels seem well-positioned to transfer products from consumers who no longer value them highly to those who do, whether they will necessarily benefit branded apparel manufacturers, or reduce the quantity of new units produced are open questions. We develop a game-theoretic infinite-horizon model in which a brand chooses production and pricing while interacting with resale channels. We first consider brand-operated resale and show that resale increases the quantity of new units only when it is also socially efficient. We then consider the impact of a third-party resale channel on a brand that does not operate its own. In this case, the brand never benefits from resale, and the possibility of resale increases output of new units for a range of intermediate transaction costs for which this is not socially efficient. Finally, we extend the analysis to competitive resale markets. While competition can replicate brand-controlled outcomes, it can also exacerbate overproduction for a range of intermediate transaction costs. Our results demonstrate that resale channels are not uniformly beneficial, especially when operated by third-parties. Without well-structured relationships between brands and resale platforms or clear policies about which products a resale platform will trade, resale may encourage overproduction. This insight should inform decisions made by brands, resale platforms, and regulators
An Application of the Archaeology of the Human Experience to Classic Period Hohokam Burials at S\u27edav Va\u27aki, Phoenix, Arizona
No full textHohokam archaeologists have long viewed the Classic Period (1100-1375 CE) in central Arizona as a time of rapid and profound change (Doyel 1981:55; Abbott 2003b). After the Pre-Classic Period (450-1100 CE), populations coalesced into massive villages each containing one or more platform mounds (Abbott et al. 2021; Bayman 1996); Hohokam farmers built and maintained one of the largest networks of canals in the Americas, and socio-political complexity reached its peak (Abbott 2003b; Abbott et al. 2006; Haury 1976). However, prosperity was tempered by possible overpopulation, drought, floods, warfare, and social change, especially in the Late Classic (Abbott 2003b; Benson and Berry 2009; Greenleaf 1975; Huckleberry et al. 2018).
Until relatively recently, most archaeologists have relied on interpretive assumptions that portray a catastrophic end to the Hohokam (Ezell 1961, 1963; Fish and Fish 2007), despite increasing evidence and widespread recognition of Hohokam cultural continuity (Loendorf and Lewis 2017). Current reconstructions offer new perspectives regarding the relationship of descendant communities, particularly the Akimel O’Odham, with Hohokam ancestors that seek to examine social change in ways that do not rely on preconceived notions of socio-political organization and social evolution (Borck and Clark 2023; Loendorf and Lewis 2017). These new approaches emphasize social change, demography, and the organizational shifts that lead to current and historical expressions of the material culture and archaeology of descendent communities. The transitional period between the late Classic Hohokam and the Post-Classic is particularly salient to these new perspectives. It was during this period that platform mounds ceased to be used as ceremonial residences and the center of population shifted south from the lower Salt River to the middle Gila River (Abbott 2002, 2003b; Doelle and Wallace 1991; Wilcox 1989).
The goal of this dissertation is to understand the factors that affected security and well-being among the Classic Period Hohokam and by examining the nature of demographic and social inequalities that emerged during the reorganization of the Hohokam cultural system. This research draws from the Archaeology of the Human Experience (AHE) to explore how people coped with rapid or widespread change and how it affected their lives (Hegmon 2016). The analysis uses field records to examine mortuary features from S’edav Va’aki (AZ U:9:1(ASM)), in Phoenix, Arizona, which was analyzed to understand several dimensions of human security including economic, food, health, and personal/community security. Economic, food, health, and personal/community security during the Hohokam Classic Period were examined using mortuary accompaniments, burial architecture, and osteological pathologies in the S’edav Va’aki dataset.
Statistical analysis of these variables revealed that in the Early Classic, there were significant demographic differences in mortuary accompaniment richness, abundance, and distribution. Adults, overwhelmingly males, had more items than subadults and females. However, this trend wanes in the Late Classic, with all demographics becoming more equal in mortuary richness, abundance, and distribution. There are no significant differences in health diachronically by sex or between the sexes in either period. Increased labor investment in burial architecture is evident over time. Based on the results of this demographic analysis, only economic security declined diachronically, primarily for adults and males.
My analyses also show that the proportion of individuals buried with an abundance of mortuary accompaniments declined over time. This suggests that rare and/or important mortuary accompaniments were concentrated in the hands of fewer individuals, including subadults, over time. The data suggest that economic security, as measured by the access to rare or important items, declined. This could indicate a reduction in trade and/or a change in social systems affected those at the top more than the general population as documented by others (see Abbott 2003a, 2003b). These conclusions mirror O’Odham oral tradition which details an accumulation of power by platform mound leaders in the Late Classic, their loss of power, and reorganization in the Post-Classic (Borck and Clark 2023; Bahr 2001).
Ultimately, this research demonstrates that human security changed over the Hohokam Classic Period in ways that have been described by descendant communities. Health security and personal/community security as measured by the variable discussed here appears to be stable through time, while economic security declined in the adult male subset of the population. This study showcases the utility of legacy collections in new archaeological research, and it also illustrates the insights that different aspects of mortuary archaeology (mortuary accompaniments, burial architecture, and health of individuals) can provide in understanding how social and environmental change affected past peoples. Additionally, this research shows the value of collaborating with descendant populations and inclusion of traditional knowledge
Analyzing the Global Happiness Index
No full textThis study explores the Global Happiness Index using data compiled from the OECD and Our World in Data to identify key factors contributing to societal well-being. Six primary predictors were analyzed: GDP per capita, social support, healthy life expectancy, freedom to make life choices, generosity, and perceptions of corruption. Regression and clustering techniques were employed to uncover patterns among countries. By expanding the analytical scope beyond conventional economic and social indicators, this study helps identify new pathways for improving well-being across diverse cultural and economic landscapes. Additional variables such as perceived safety, political engagement, and values related to family and leisure were integrated to enrich the analysis. Environmental quality and income inequality were also considered to provide a more comprehensive view of life satisfaction determinants. Our findings highlight the most statistically significant predictors of happiness and reveal two primary country clusters: one characterized by traditional values and lower satisfaction, and another marked by modern, leisure-oriented societies with higher well-being. These insights offer a data-driven framework for comparing nations and understanding the multidimensional nature of happiness. Ultimately, this analysis provides actionable recommendations for policymakers aiming to implement more targeted, effective, and sustainable interventions to improve life satisfaction globally
Procedural Terrain Generation with Biome Ecosystem and Dynamic Weather
No full textThis thesis introduces a procedural terrain generation tool, inspired by immersive game environments such as The Elder Scrolls V: Skyrim and Ghost of Tsushima. It combines procedural terrain and biome generation algorithms with dynamic weather transitions, allowing user customization through editing and importing heightmaps and biome maps. The system employs procedural functions like Perlin and fractal noise to generate realistic, varied landscapes and ecosystems, with vegetation distributed according to biome-specific parameters. Terrain mesh creation leverages detailed heightmap information, enhanced by advanced rendering techniques including normal mapping via central difference calculations, mip-mapping, and anisotropic filtering. Additionally, the tool features GPU-based dynamic rain effects and seamless skybox transitions for weather and time-of-day variations. Designed for flexibility and artistic control, this editor facilitates rapid creation and iteration of dynamic terrains for game developers aiming to efficiently build rich, interactive worlds