In our January-February 2007 column we discussed a disturbing development for tax practitioners: the growth of the tax strategy patent industry. In that column, we reviewed how for a patent to issue an innovation be “nonobvious” such that it would not be an improvement that would be obvious to a person having ordinary skill in the pertinent art. We also explained how the Court in State Street Bank and Trust Co. v. Signature Financial, Inc. created the right to patent business methods. Neal Gerber Eisenberg partner and Private Wealth Services chair Lawrence I. Richman authored an article that appears in the January-February 2009 edition of CCH's Journal of Passthrough Entities.