The United States Patent Act, which appears in Section 35 of the United States Code, extends protection to "any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof...." 35 U.S.C. 101. Patent applicants must convince the Patent and Trademark Office that their invention meets the statutory test for novelty, id. 102, and unobviousness, id. 103, and must describe their invention in a way that enables a person of ordinary skill to practice the invention, id. 112 2.