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WHAT IS PATENT ELIGIBLE?. In re Bilski and its Impacts on the Patent Landscape. In re Bilski. Part 1.Background Part 2.The Bilski Decision Part 3. Impact on Business Methods and Software Patents Part 4.Impact on Diagnostic Methods Part 5.Strategies. In re Bilski.

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What is patent eligible

WHAT IS PATENT ELIGIBLE?

In re Bilski and its Impacts on the Patent Landscape


In re bilski

In re Bilski

  • Part 1.Background

  • Part 2.The Bilski Decision

  • Part 3. Impact on Business Methods and Software Patents

  • Part 4.Impact on Diagnostic Methods

  • Part 5.Strategies

Nutter McClennen & Fish LLP • www.nutter.com


In re bilski1

In re Bilski

Part 1, Background


A little history

A Little History

  • Patent Act of 1793

  • a patent may be granted to any person or persons who “shall allege that he or they have invented any new and useful art, machine, manufacture or composition or matter, or any new and useful improvement on any art, machine, manufacture or composition of matter. . . . (1 Stat. 318, 319 § 1 (1793)).

  • Criteria remained essentially unchanged until 1952, when Congress amended § 101 as follows:

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1952 patent act process

1952 Patent Act – “Process”

  • 35 U.S.C. § 101

  • Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.

  • 35 U.S.C. § 100(b)

  • The term “process” means process, art, or method, and includes a new use of a known process, machine, manufacture, composition of matter, or material.

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Enter the computer gottschalk v benson 409 u s 63 1972

Enter the Computer:Gottschalk v. Benson, 409 U.S. 63 (1972)

  • Patent claims a method for converting binary-coded decimal (BCD) numerals into pure binary numerals.

    • Claims were not limited to any particular art or technology, to any particular apparatus or machinery, or to any particular end use.

    • Claims purported to cover any use of the claimed method in a general purpose digital computer of any type.

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Pre 195 benson cont

Pre-195Benson (cont.)

“It is conceded that one may not patent an idea. But, in practical

effect, that would be the result if the formula for converting BCD

numerals to pure binary numerals were patented in this case. The

mathematical formula involved here has no substantial practical

application except in connection with a digital computer, which

means that, if the judgment below is affirmed, the patent would

wholly preempt the mathematical formula and, in practical effect,

would be a patent of the algorithm itself.”

Gottschalk v. Benson, 409 U.S. 63, 71-72 (1972)

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Benson cont

Benson (cont.)

“It is argued that a process patent must either be tied to a particular machine or apparatus or must operate to change articles or materials to a "different state or thing." We do not hold that no process patent could ever qualify if it did not meet the requirements of our prior precedents. . . . It is said we freeze process patents to old technologies, leaving no room for the revelations of the new, onrushing technology. Such is not our purpose. . . .”

Gottschalk v. Benson, 409 U.S. 63, 71 (1972)

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Pre 195 diamond v diehr 450 u s 175 1981

Pre-195Diamond v. Diehr, 450 U.S. 175, (1981)

A method of operating a rubber-molding press for precision molded compounds with the aid of a digital computer, comprising:. . . ;repetitively comparing in the computer, at frequent intervals during each cure, the Arrhenius equation for reaction time during the cure, which is ‘ln v = CZ +x’,repetitively comparing in the computer at frequent intervals during the cure each said calculation of the total required cure time calculated with the Arrhenius equation and said elapsed time, and

opening the press automatically when a said comparison indicates completion of curing.

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Pre 195 diehr cont

Pre-195Diehr (cont.)

  • Claim is patentable:

    “Arrhenius equation is not patentable in isolation, but when a process for curing rubber is devised which incorporates in it a more efficient solution of the equation, that process is at the very least not barred at the threshold by § 101.”

    Diamond v. Diehr, 450 U.S. 175, 188 (1981)

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Pre 195 state street

Pre-195State Street

  • State Street Bank v. Signature Financial Group, Inc., 149 F.3d 1368 (1998)

  • Provides a system (“Hub and Spoke”) which facilitates a structure whereby mutual funds (spokes) pool their assets in an investment portfolio (Hub) organized as a partnership

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Useful concrete and tangible

“Useful, Concrete, and Tangible”

“Today, we hold that the transformation of data, representing discrete dollar amounts, by a machine through a series of mathematical calculations into a final share price, constitutes a practical application of a mathematical algorithm, formula, or calculation, because it produces "a useful, concrete and tangible result"--a final share price momentarily fixed for recording and reporting purposes and even accepted and relied upon by regulatory authorities and in subsequent trades.”

State Street, 149 F.3d 1368, 1373 (1998)

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Pre 195 state street to bilski

Pre-195State Street to Bilski

  • According to Justice Newman’s dissent in Bilski, almost 40,000 Business Method patent applications filed since State Street decision.

  • As noted in Justice Mayer’s dissent in Bilski, issued patents include:

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Pre 195 state street to bilski1

Pre-195State Street to Bilski

  • U.S. Patent 6,119,099 (method of enticing customers to order additional food at a fast food restaurant)

  • U.S. Patent No. 6,329,919 (system for toilet reservations)

  • U.S. Patent No. 7,261,652 (method of putting a golf ball)

  • U.S. Patent No. 6,368,227 (method of swinging on a swing)

  • U.S. Patent No. 5,443,036 (method of inducing cats to exercise)

  • U.S. Patent No. 6,049,811 (method of obtaining a patent)

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In re bilski2

In re Bilski

Part 2, The CAFC Decision


In re bilski3

In re Bilski

  • Claim 1: A method for managing the consumption risk costs of a commodity sold by a commodity provider at a fixed price comprising the steps of:(a) initiating a series of transactions between said commodity provider and consumers of said commodity wherein said consumers purchase said commodity at a fixed rate based upon historical averages, said fixed rate corresponding to a risk position of said consumer;(b) identifying market participants for said commodity having a counter-risk position to said consumers;(c) initiating a series of transactions between said commodity provider and said market participants at a second fixed rate such that said series of market participant transactions balances the risk position of said series of consumer transactions.

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Examiner s rejections

Examiner’s Rejections

  • The Examiner rejected claims 1-11 under 35 U.S.C. 101

  • The Examiner’s rational:

  • “[r]egarding … claims 1-11, the invention is not implemented on a specific apparatus and merely manipulates an abstract idea and solves a purely mathematical problem without any limitation to a practical application, therefore, the invention is not directed to technological arts.”

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What is patent eligible

Board’s Decision

  • The Board held the Examiner erred to the extent that he relied on a “technological arts” test because the case law did not support such a test

  • The Board also held that the requirement of a specific apparatus was also erroneous as a claim that does not recite a specific apparatus may still be patent-eligible if it transforms physical subject matter from one state to another (e.g., “’mixing’ two elements or compounds to produce a chemical substance or mixture is clearly a statutory transformation …”)

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Board s decision cont

Board’s Decision (cont.)

  • The Board, however, concluded that Applicants’ claims did not involve any patent-eligible transformation as they were merely directed to “non-physical financial risks and legal liabilities of the commodity provider, the consumer, and the market participants.”

  • The Board also held that Applicants’ claims “preempt[] any and every possible way of performing the steps of the [claimed process], by human or by any kind of machine or by any combination thereof…,” and hence an abstract idea ineligible for patenting

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Board s decision cont1

Board’s Decision (Cont.)

  • The Board also held that the claimed process did not produce “useful, concrete, tangible result,” and for this reason also was not directed to patent-eligible subject matter.

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What is patent eligible

CAFC

  • The Supreme Court has held that the meaning of “process” as used in Section 101 in narrower that its ordinary meaning.

  • The Supreme Court has held that a claim is not a patent-eligible “process” if it claims “laws of nature, natural phenomena, [or] abstract ideas.”

  • “The true issue before us is then whether Applicants are seeking to claim a fundamental principle (such as an abstract idea) or mental process”

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Cafc cont

CAFC (cont.)

  • “Diehr can be understood to suggest that whether a claim is drawn only to a fundamental principle is essentially an inquiry into scope of that exclusion; i.e., whether the effect of allowing the claim would be to allow the patentee to pre-empt substantially all uses of that fundamental principle.”

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Cafc cont1

CAFC (cont.)

  • How does one determine whether a claimed process would pre-empt all uses of a fundamental process?

  • Machine-or-Transformation test:

  • (1) is the claimed process tied to a particular machine or apparatus?

  • (2) does it transform a particular article into a different state or thing?

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Cafc cont2

CAFC (cont.)

  • “We hold that the Applicants’ process as claimed does not transform any article to a different state or thing.”

  • “Purported transformations or manipulations simply of public or private legal obligations or relationships, business risks, or other such abstractions cannot meet the test because they are not physical objects or substances, and they are not representative of physical objects or substances.”

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Cafc cont3

CAFC (cont.)

  • The claim “is not limited to transactions involving actual commodities, and the application discloses that the recited transaction may simply involve options, i.e., rights to purchase or sell the commodity at a particular price within a particular timeframe”

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Cafc cont4

CAFC (cont.)

  • “… it is inappropriate to determine the patent-eligibility of claim as a whole based on whether selected limitations constitute patent-eligible subject matter.”

  • “… the use of a specific machine or transformation of an article must impose meaningful limits on the claim’s scope to impart patent-eligibility”

  • “… the involvement of the machine or transformation in the claimed process must not merely be insignificant extra-solution activity.”

  • “We leave to the future cases the elaboration of the precise contours of machine implementation, as well as the answers to particular questions, such as whether or when recitation of a computer suffices to tie a process claim to a particular machine.”

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Cafc cont5

CAFC (cont.)

  • In Benson, the claimed process, though tied to a machine, was found not to be patent eligible

  • In Benson, “… the limitations tying the process to a computer were not actually limiting because the fundamental principle at issue, a particular algorithm, had no utility other than operating on a digital computer.”

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Cafc cont6

CAFC (cont.)

  • “It is virtually self-evident that a process for a chemical or physical transformation of physical objects or substances is patent-eligible subject matter.”

  • “The raw materials of many information-age processes, however, are electronic signals and electronically-manipulated data.”

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Cafc cont7

CAFC (cont.)

  • A broad independent claim reciting a process of graphically displaying variances of data from average values was held patent ineligible. In re Abele, 684 F.2d 902 (CCPA 1982)

  • “The claim did not specify any particular type or nature of data…”, and “… nor did it specify how or from where the data was obtained or what the data represented.”

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Cafc cont8

CAFC (cont.)

  • One of Abele’s dependent claim reciting “said data is X-ray attenuation data produced in a two dimensional field by a computed tomography scanner” was deemed patent eligible

  • “This data clearly represented physical and tangible objects …”

  • “… transformation of that raw data into a particular visual depiction of a physical object on a display was sufficient …” for patent eligibilty

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Cafc cont9

CAFC (cont.)

  • Certain active steps, such as gathering data and/or recording output data, may be construed as insignificant “extra-solution activity” and hence insufficient to render an otherwise patent-eligible claim into a patent-eligible one

  • “This court and our predecessor court have frequently stated that adding a data-gathering step to an algorithm is insufficient to convert that algorithm into a patent-eligible process.”

  • “A requirement simply that data inputs be gathered – without specifying how – is a meaningless limit on a claim to an algorithm because every algorithm inherently requires the gathering of data inputs.”

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Cafc cont10

CAFC (cont.)

  • Method of conducting an auction of multiple items in which the winning bids were selected in a manner that maximized the total price of all items. In re Schrader, 22 F.3d 290 (Fed. Cir. 1994)

  • Claims were patent-ineligible as being merely directed to a mathematical optimization algorithm.

  • No specific machine or apparatus was recited.

  • The claimed method did require a step of recording bids on each item, though no particular manner of recording was specified.

  • The step of recording the bids constituted “extra-solution activity.”

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Cafc cont11

CAFC (cont.)

  • “Nevertheless, we agree that future developments in technology and the sciences may present difficult challenges to the machine-or-transformation test …”

  • “Thus, we recognize that the Supreme Court may ultimately decide to alter or perhaps even set aside this test to accommodate emerging technologies.”

  • “And we certainly do not rule out the possibility that this court may in the future refine or augment the test or how it is applied.”

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In re bilski4

In re Bilski

Part 3, Impact on Business Methods and Software Patents


Future of business methods

Future of Business Methods

  • End of Business Method patents?

  • Transformation of Legal Relationships and Business Obligations

    • Abstract; Not Tangible

  • Is there a Machine?

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    Cybersource corporation v retail decisions 2009 u s dist lexis 26056

    Cybersource Corporation v. Retail Decisions, 2009 U.S. Dist. LEXIS 26056

    3. A method for verifying the validity of a credit card transaction over the Internet comprising the steps of: a) obtaining other transactions utilizing an Internet address that is identified with the credit card transaction; b) constructing a map of credit card numbers based upon the other transactions and; c) utilizing the map of credit card numbers to determine if the credit card transaction is valid.

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    Cybersource corporation cont

    Cybersource Corporation (cont.)

    • No Transformation; court finds that “manipulation” of data is not transformation

      • “’Transformation’ suggests a fundamental change, whereas ‘manipulation’ does not. . . . Simply collecting data into a vague sort of ‘map’ does not amount to a transformation.”

      • Even if manipulation could be considered transformation, there is no transformation of an article “i.e., any physical object or substance, or any electronic signal representative of any physical object or substance.”

  • No machine; internet is not a particular machine

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    Cybersource corporation cont1

    Cybersource Corporation (cont.)

    • As for the future of Business Method patents:

      • “In analyzing Bilski, one is led to ponder whether the end has arrived for business method patents, whose numbers swelled following the decision in State Street. . . . Although the majority declined say so explicitly, Bilski’s holding suggests a perilous future for most business method patents.”

      • “. . . The closing bell may be ringing for business method patents, and their patentees may find they have become bagholders.”

    Nutter McClennen & Fish LLP • www.nutter.com


    In re ferguson fed cir march 6 2009

    In re Ferguson (Fed. Cir.) March 6, 2009

    • A method of marketing a product, comprising:

      developing a shared marketing force, said shared marketing force including at least marketing channels, which enable marketing a number of related products;

      using said shared marketing force to market a plurality of different products that are made by a plurality of different autonomous producing company, so that different autonomous companies, having different ownerships, respectively produce said related products;

      obtaining a share of total profits from each of said plurality of different autonomous producing companies in return for said using; and

      obtaining an exclusive right to market each of said plurality of products in return for said using.

    Nutter McClennen & Fish LLP • www.nutter.com


    Software patents

    Software Patents

    • Is a Computer a “Machine”?

      • If so, how detailed do you need to be?

  • Is there a “Transformation” of an “Tangible Article”?

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    Every penny counts v boa may 2009

    Every Penny Counts v. BOA (May 2009)

    • A system, comprising: a network; entry means coupled to said network for entering into the network an amount being paid in a transaction by a payor; . . . said computing means in said network being responsive to said data and said identification entering means for determining an excess payment to the basis of the determinant established by the payor, and said computing means in said network being responsive to the excess payment for apportioning at least a part of the excess payment among said accounts on the basis of the excess determined and established by the payor and on the basis of commands established by the payor and controlled by other than the payee.

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    Ex parte nawathe february 9 2009

    Ex parte Nawathe, February 9, 2009

    • Ex parte Nawathe (February 9, 2009)

    • Representative claim:

    • A computerized method comprising:inputting multiple extensible Markup Language (XML) documents;creating a data representation of said multiple XML documents; andreducing redundancy across said multiple XML documents via a fixed set of tables.

    • Rejection Affirmed

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    Ex parte nawathe cont

    Ex parte Nawathe (cont.)

    • No machine; just a general purpose computer

    • No transformation because documents are not articles

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    Ex parte halligan april 8 2009

    Ex parte Halligan, April 8, 2009

    • A programmed computer method based upon the six factors of a trade secret from the First Restatement of Torts for providing documentation, analysis, auditing, accounting, protection, and other management relating to an existence, . . . of a plurality of trade secrets of an organization, said method implemented by the programmed computer to effect the following steps:

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    Ex parte halligan cont

    Ex parte Halligan, (cont)

    • Fails both prongs

      • Merely a general purpose computer

      • No transformation because numerical value assigned by computer is abstract – not a “tangible article”

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    In re shahabi april 20 2009

    In re Shahabi, April 20, 2009

    • 1.A method, comprising:

    • processing at least one query using a wavelet transformation to produce a transformed query; and

    • performing a range-sum query on a database using the transformed query to produce a result.

    • No machine

    • No transformation

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    In re richter may 29 2009

    In re Richter, May 29, 2009

    • 21. In a host multiprocessor system for emulating the operation of a target n-processor system (n>1) by execution of one of more threads representing the operation of the target system, a method for emulating the target system’s memory addressing using a virtual-to-real memory mapping mechanism of the host multiprocessor system’s operating system, said method comprising:

    • (a) reading a target system virtual memory address (ATV);

    • (b) mapping said ATV to a target real address (ATR);

    • (c) mapping said ATR to a host virtual memory address (AHV); and

    • (d) mapping said AHV to a host real memory address, wherein the emulation of the target system’s memory addressing is treated as an application running on the host multiprocessor system.

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    In re richter cont

    In re Richter, (cont.)

    • “Claim 21 recites a method performed in a host multiprocessor system that emulates a target n-processor system; therefore the process claim includes use of a specific machine. ”

    • “. . . We further find use of the specific machine imposes meaningful limits on the scope of the claims – the host processor emulates a target system’s memory addressing causing it to behave like the target processor.”

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    In re bilski5

    In re Bilski

    Part 4, Implications for Diagnostic Methods


    Diagnostic methods

    Diagnostic Methods

    • The application of “machine-or-transformation” test to diagnostic methods can curtail the scope of available patent protection

    • Diagnostic methods typically involve diagnosing disease conditions and/or optimizing therapeutic treatments based on comparative inferences and/or correlations between various biochemical compounds and/or markers

    • Under a narrow interpretation of the test the identification of such inferences and correlations can be deemed as discovery of natural phenomena without transforming an article from one state to another

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    Classen immunotherapies inc v biogen idec

    Classen Immunotherapies, Inc. v. Biogen Idec.

    • Classen patents were directed to a process of identifying lower risk vaccines (U.S. Patent Nos. 5,723,283; 5,728,385; 6,638,739; 6,420,139)

    • A method of determining whether an immunization schedule affects the incidence or severity of a chronic immune-mediated disorder in a treatment group of mammals, relative to a control group of mammals, which comprises immunizing mammals in the treatment group of mammals with one or more doses of one or more immunogens, according to said immunization schedule, and comparing the incidence, prevalence, frequency or severity of said chronic immune-mediated disorder or the level of a marker of such a disorder, in the treatment group, with that in the control group. (claim 1 of ‘283 patent)

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    Classen immunotherapies inc v biogen idec supp 2d 452 2005 u s dist lexis 17075 d md 2005

    Classen Immunotherapies, Inc. v. Biogen Idec, Supp. 2d 452, 2005 U.S. Dist. LEXIS 17075 (D. Md 2005)

    • “Although articulated as a process, the 283 patent does not claim a specific technique or technical process of testing vaccine safety. Instead, the 283 patent describes only a general inquiry of whether the proposed correlation … exists.”

    • “Clearly, the correlation between vaccination schedules and the incidence of immune mediated disorders that Dr. Classen claims to have discovered is a natural phenomenon.”

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    Classen

    Classen

    • “As such, the process is indistiguishable from the idea itself. Accordingly, the 283 patent seeks to patent an unpatentable natural phenomenon.”

    • The 139 and 739 patents were also deemed as patent-ineligible even though they included the active step of immunizing patients in accordance with a schedule determined to be low risk

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    Classen immunotherapies inc v biogen idec 304 fed appx 866 2008 u s app lexis 25661 fed cir 2008

    Classen Immunotherapies, Inc. v. Biogen Idec, 304 Fed. Appx. 866, 2008 U.S. App. LEXIS 25661 (Fed. Cir. 2008)

    • “In light of our decision in In re Bilski …, we affirm the district court’s grant of summary judgment that these claims are invalid under 35 U.S.C. 101.”

    • Classen’s claims are neither tied to a particular machine or apparatus, nor do they transform a particular article into a different state or thing

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    Prometheus laboratories inc v mayo collaborative services fed supp 2d 2008 wl 878910 s d cal 2008

    Prometheus Laboratories Inc. v. Mayo Collaborative ServicesFed. Supp. 2d, 2008 WL 878910 (S.D.Cal 2008)

    • Patents were directed to methods of measuring the level of certain metabolites (6-thioguinine and 6-methylmercaptopurine) in blood of patients taking certain drugs for autoimmune diseases and indicating that the adjustment of the drug dosage may be required based on the measurements to avoid toxic side effects. U.S. Patent Nos. 6,355,623 and 6,680,302

    • The claims embody only the correlations between the level of metabolites and therapeutic efficacy and toxicity in patients taking the drug.

    • The court deems the correlations deemed as “natural phenomena.”

    • Patents are invalid as directed to patent-ineligible subject matter.

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    In re bilski6

    In re Bilski

    Part 5, Strategies


    Tips for success

    Tips for Success

    • Keep Filing Patent Applications

    • Include Sufficient Disclosure

      • How is data gathered?

      • What does data represent?

      • How is data transformed?

    • Draft Claims In View of Recent PTO Guidelines

    • Include Claims of Varying Scope

    • Review Existing Portfolio

    • Watch For the Supreme Court Decision

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    The end

    The End

    • Thank you

    • Thomas Engellenner

    • Reza Mollaaghababa

    • Michael Doyle

    • Nutter, McClennen & Fish, LLP

    • Boston

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