CardioNet, LLC v. InfoBionic, Inc.
United States Court of Appeals for the Federal Circuit
April 17, 2020, Decided
[*1361] Stoll, Circuit Judge.
CardioNet, LLC and Braemar Manufacturing, LLC (collectively, "CardioNet") appeal the district court's dismissal of their patent infringement complaint against InfoBionic, Inc. The district court held that the asserted claims of CardioNet's U.S. [*1362] Patent No. 7,941,207 are ineligible under 35 U.S.C. § 101, and therefore the complaint failed to state a claim under Federal Rule of Civil Procedure 12(b)(6). We conclude instead that the asserted claims of the '207 patent are directed to a patent-eligible improvement to cardiac monitoring technology and are not directed to an abstract idea. Accordingly, we [**2] reverse the district court and remand for further proceedings.
Anomalies in the electrical activity of a patient's heart can indicate the presence of certain physiological conditions ranging from benign to life-threatening. Among those conditions are various different types of cardiac arrythmias (abnormal heart rhythms), including atrial fibrillation, atrial flutter, normal sinus rhythm irregularity, irregularity from various types of heart blocks, irregularity associated with premature ventricular contractions, and ventricular tachycardia.
Atrial fibrillation and atrial flutter involve "the loss of synchrony between the atria and the ventricles" of the heart. '207 patent col. 1 ll. 24-25, 34-35. A patient may experience "short" or "sustained" episodes of atrial fibrillation or atrial flutter. Short episodes "generally include between two and 20 [heart]beats and may or may not have clinical significan[ce]." Id. at col. 5 ll. 33-35. By contrast, sustained episodes "generally include more than 20 beats and may have relatively greater clinical significance." Id. at col. 5 ll. 35-37. Atrial fibrillation "can lead to irregular ventricular beating as well as blood stagnation and clotting in [**3] the atria." Id. at col. 1 ll. 27-28. Both atrial fibrillation and atrial flutter are "associated with stroke, congestive heart failure, and cardiomyopathy." Id. at col. 1 ll. 31-32, 40-42.
Ventricular tachycardia, or V-TACH, is another form of cardiac arrythmia and is characterized by "a rapid succession of ventricular contractions (e.g., between 140 and 220 per minute) generally caused by an abnormal focus of electrical activity in a ventricle." Id. at col. 9 ll. 41-44. Ventricular beats "are irregular beats that interrupt the normal heart rhythm" and that "may be precipitated by factors such as alcohol, tobacco, caffeine, and stress." Id. at col. 9 ll. 10-12, 19-20. The "occurrence of ventricular beats can be used to identify ventricular tachycardia (e.g., when there are three or more consecutive ventricular beats)." Id. at col. 9 ll. 16-19. V-TACH "can last from a few seconds to several days and can be caused by serious heart conditions such as a myocardial infarction." Id. at col. 9 ll. 44-46.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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955 F.3d 1358 *; 2020 U.S. App. LEXIS 12240 **; 2020 U.S.P.Q.2D (BNA) 10367
CARDIONET, LLC, BRAEMAR MANUFACTURING, LLC, Plaintiffs-Appellants v. INFOBIONIC, INC, Defendant-Appellee
Prior History: [**1] Appeal from the United States District Court for the District of Massachusetts in No. 1:17-cv-10445-IT, Judge Indira Talwani.
Cardionet, LLC v. Infobionic, Inc., 348 F. Supp. 3d 87, 2018 U.S. Dist. LEXIS 177305 (D. Mass., Oct. 16, 2018)
Disposition: REVERSED AND REMANDED.
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Civil Procedure, Appeals, Standards of Review, De Novo Review, Defenses, Demurrers & Objections, Motions to Dismiss, Failure to State Claim, Patent Law, Jurisdiction & Review, Subject Matter