Cardionet, LLC, and Braemar Manufacturing, LLC v. Infobionic, Inc., 15-cv-11803 (Talwani, J.) (E.D. Tex. May. 4, 2017)
- 7,212,850 | Entitled, “System and Method for Processing and Presenting Arrhythmia Information to Facilitate Heart Arrhythmia Identification and Treatment”
- 7,907,996 | Entitled, “System and Method for Processing and Presenting Arrhythmia Information to Facilitate Heart Arrhythmia Identification and Treatment”
- RE43,767 | Entitled, “Control of Data Transmission Between a Remote Monitoring Unit and a Central Unit”
- 7,099,715 | Entitled, “Distributed Cardiac Activity Monitoring with Selective Filtering”
Court granted Defendant’s motion for judgment on the pleadings for two claims at issue, but found that the remaining claims were not adequately briefed and ordered additional briefing if parties could not come to agreement as to whether invalidated claims were representative of the remaining claims.
No to some; yes to others
Gathering a limited set of patient data and then determining whether it is necessary to gather additional data.
The court found the ‘767 patent was targeted at “the age-old concept of gathering a limited set of patient data and then determining whether it is necessary to gather additional data,” but found that it was unable to determine as a matter of law whether the claims laked an inventive concept.
The court further found that Claim 31 of the ’850 Patent and Claim 12 of the ’996 Patent are directed to the abstract idea of correlating one set of data to another. It then noted that the claims simply directed a user to use conventional hardware and routine steps to execute the abstract idea. Accordingly, the claim were found invalid under § 101.
The court found that the claims of the ‘715 Patent were directed at abstract idea of filtering raw cardiogram data to optimize its output, rather than a specific improvement in the existing mobile cardiac telemetry field. Nevertheless, the claims disclosed a novel set of computer components that meet the machine or transformation test and therefore was sufficiently inventive.