Cardionet, LLC v. Infobionic, Inc, Appeal No. 2019-1149 (Fed. Cir. Decided April 17, 2020) (Precedential)

June 17, 2020
Presented By
  • Alireza Behrooz, Ph.D.

Earlier, a district court had held that the asserted claims of CardioNet’s U.S. Patent No. 7,941,207 covering a device for detecting and reporting the presence of atrial fibrillation or atrial flutter in the heart of a patient are ineligible under 35 U.S.C. § 101. However, without hardly missing a heartbeat, a Federal Circuit majority in a precedential opinion reversed the district court, concluding 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.  Moreover, the majority clarified that step one of the Alice frame-work does not require an evaluation of the prior art or facts outside of the intrinsic record regarding the state of the art at the time of the invention. The presentation will discuss the decision, together with its ramifications, along with a brief review of the two-step test for examining patent eligibility.

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