Baxter Int'l, Inc. v. Carefusion Corp.

Baxter Int'l, Inc. v. Carefusion Corp., No. 15-CV-09986, 2016 WL 2770787, at *1 (N.D. Ill. May 13, 2016)

Patent(s):   

  • 5,764,034 | Entitled “Battery gauge for a battery operated infusion pump”
  • 6,321,560 | Entitled “Method and Apparatus For Automatically Controlling The Level of Medication” 

Disposition:               

Motion to dismiss for invalidity denied. 

Abstract Idea:

No for both patents.

Something More:

Yes for both patents.

Technology:              

Method of monitoring battery levels in medical infusion pumps (‘034 patent); Method and Apparatus For Automatically Controlling The Level of Medication (‘560 patent). 

Summary:                 

Applying the first step of the Alice test, the Court found the ‘034 patent to be valid under § 101 because the claim was “directed to a concrete, tangible instrument that utilizes a sampling detection technique, measuring battery voltage and current drain to determine the time of remaining battery life and to issue applicable alert messages.” Thus, the claims involved patentable subject matter, not abstract ideas. The court went on to say that even if the ‘034 patent was viewed as an abstract idea, the method would still be patent-eligible under second step of the Alice test. This is in part because the method satisfied the “machine-or-transformation test,” in that the method was intrinsically tied to mechanical and electrical devices. This transforms the idea into something "significantly more" than mere calculation and thus makes the method patent-eligible subject matter.

The Court similarly applied the first step of the Alice test to find the ‘560 patent to be valid under § 101 because the claims “incorporate physical and tangible components directed towards a particular application — specifically, an improved infusion pump system capable of automatic, dynamic adjustment of a patient's medicine based on his or her condition.” The concrete nature and discrete field of application distinguished this patent from other, ineligible patents directed at disembodied data collection and data processing methods. Again, the Court went on to hold that even if ‘560 was deemed an abstract idea, it still met the criteria for eligibility under the second step of the Alice test. Relying on the machine-or-transformation test again, the Court found that the claims were tied to a particular machine and apparatus, satisfying the second step of Alice and making the method patent-eligible.