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Cardionet, LLC v. Infobionic, Inc.

Representative Claim(s)

U.S. 7,941,207 – claim 1

  1. A device, comprising:
    a beat detector to identify a beat-to-beat timing of cardiac activity;
    a ventricular beat detector to identify ventricular beats in the cardiac activity;
    variability determination logic to determine a variability in the beat-to-beat timing of a collection of beats;
    relevance determination logic to identify a relevance of the variability in the beat-to-beat timing to at least one of atrial fibrillation and atrial flutter; and
    an event generator to generate an event when the variability in the beat-to-beat timing is identified as relevant to the at least one of atrial fibrillation and atrial flutter in light of the variability in the beat-to-beat timing caused by ventricular beats identified by the ventricular beat detector.

Posture:

Appeal from District Court’s Dismissal

Exception Category: None

“When read as a whole, and in light of the written description, we conclude that claim 1 of the ʼ207 patent is directed to an improved cardiac monitoring device and not to an abstract idea. In particular, the language of claim 1 indicates that it is directed to a device that detects beat-to-beat timing of cardiac activity, detects premature ventricular beats, and determines the relevance of the beat-to-beat timing to atrial fibrillation or atrial flutter, taking into account the variability in the beat-to-beat timing caused by premature ventricular beats identified by the device’s ventricular beat detector. In our view, the claims ‘focus on a specific means or method that improves’ cardiac monitoring technology; they are not ‘directed to a result or effect that itself is the abstract idea and merely invoke generic processes and machinery.’ McRO, 837 F.3d at 1314 (citations omitted).”

CardioNet, LLC v. InfoBionic, Inc., 955 F.3d 1358, 1368 (Fed. Cir. 2020).

“The ʼ207 patent claims are also similar to those we held eligible in McRO. The patent at issue in McRO claimed a “method for automatically animating lip synchronization and facial expression of three-dimensional characters.” 837 F.3d at 1307. We reversed the district court’s grant of judgment on the pleadings under Federal Rule of Civil Procedure 12(c) that the claims were directed to an abstract idea. We held under Alice step one that the claims were directed to ‘a specific asserted improvement in computer animation, i.e., the automatic use of rules of a particular type.’ Id. at 1314. The written description confirmed that the ‘claimed improvement’ was ‘allowing computers to produce accurate and realistic lip synchronization and facial expressions in animated characters that previously could only be produced by human animators.’ Id. at 1313 (internal quotation marks and citation omitted). We rejected the argument that the claims ‘simply use a computer as a tool to automate conventional activity’ because there was no evidence in the record that ‘the process previously used by animators [wa]s the same as the process required by the claims.’ Id. at 1314. The specification made ‘no suggestion that animators were previously employing the type of rules required by’ the claims. Id. In fact, the evidence in the record showed that the traditional process and claimed method produced realistic animations of facial movements in fundamentally different ways. Id.

In this case, there is likewise no suggestion in the ʼ207 patent’s written description that doctors were ‘previously employing’ the techniques performed on the claimed device. Nothing in the record in this case suggests that the claims merely computerize pre-existing techniques for diagnosing atrial fibrillation and atrial flutter. Moreover, as in McRO, the written description of the ʼ207 patent confirms that the asserted claims are directed to a specific technological improvement—an improved medical device that achieves speedier, more accurate, and clinically significant detection of two specific medical conditions out of a host of possible heart conditions.”

CardioNet, LLC v. InfoBionic, Inc., 955 F.3d 1358, 1370 (Fed. Cir. 2020).