It could always have been read broadly, but was it in practice?
Wikipedia brought up the 1908 Hotel Security Checking Co. v. Lorraine Co and the 1950 Joseph E. Seagram & Sons v. Marzell as examples of cases where courts rejected patents on business methods. Furthermore the USPTO for many years would not accept such patent applications. Not out of capriciousness, but because they really thought that such patents would not pass legal muster.
These stand as examples showing that 35 USC 101 was not always read as broadly as it is being read today.
It could always have been read broadly, but was it in practice?
Wikipedia brought up the 1908 Hotel Security Checking Co. v. Lorraine Co and the 1950 Joseph E. Seagram & Sons v. Marzell as examples of cases where courts rejected patents on business methods. Furthermore the USPTO for many years would not accept such patent applications. Not out of capriciousness, but because they really thought that such patents would not pass legal muster.
These stand as examples showing that 35 USC 101 was not always read as broadly as it is being read today.