Below is further information about the patent case, America Holdings v.
Metabolite Laboratories, Inc., about which I previously made a post earlier
today. Also, I have inculded a link to the Supreme Court web site where the
decision can be read in its entirity. Further, there is a link where one can
subscribe to a mailing list.
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The court's recent opinions can be found at:
http://www.supremecourtus.gov/opinions/05slipopinion.html
See also:
http://www.supremecourtus.gov/opinions/opinions.html
Transcripts of the oral arguements can be found at:
http://www.supremecourtus.gov/oral_arguments/argument_transcripts.html
Submitted briefs can be found at:
http://supreme.findlaw.com/supreme_court/briefs/index.html
NOTE: Briefs from the current term are not yet available. Also see:
http://www.supremecourtus.gov/oral_arguments/briefsource.pdf
http://www.usdoj.gov/osg/briefs/2005/3mer/1ami/2004-0607.mer.ami.pdf (Amicus
brief submitted by the United States)
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America Holdings v. Metabolite Laboratories, Inc.
Decided: 06/22/06
No. 04-607
Full text:
http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=000&invol=04-607
PATENT LAW (The United States Supreme Court Dismisses the Writ of
Certiorari As Improvidently Granted)
The United States Supreme Court held per curiam (dissent by Breyer,
Roberts took no part in this decision) that writ of certiorari was
improvidently granted to decide whether a party is liable for patent
infringement when a step directing a party to correlate test results is
arguably vague and indiscernible.
The patent at issue in this case (the patent), covers a total homocysteine
test and a total homocysteine methylmalonic acid test. Doctors use these
tests to identify vitamin deficiencies in patients. University Patents
Inc. licensed the patent to respondent, Metabolite Laboratories
(Metabolite,) who then sublicensed the patent to Laboratory Corp.
(Laboratory). In 1998, Laboratory switched to a similar test developed by
Abbot Laboratories and discontinued royalty payments to Metabolite for the
test. Metabolite sued in the United States District Court for the District
of Colorado (District Court) for patent infringement. The jury found that
Laboratory breached its license agreement with Metabolite and infringed
the patent. The United States Court of Appeals for the Federal Circuit
(Court of Appeals) affirmed, holding that the prosecution history and
claim language supported the interpretation that correlating included both
a mutual and reciprocal relationship, and not just a mutual relationship.
In addition, the Court of Appeals held that the language was clear and
produced a discernible and clear meaning. The United States Supreme Court
(the Court) granted certiorari limited to Question three of the petition,
which asked whether a method patent containing vague steps for diagnosis
can validly claim a monopoly over a basic scientific procedure used in
medical treatment. Later, the Chief Justice advised the Court that he
should have recused himself from participation in this case. The Court
reconsidered the petition and again granted petition for certiorari
limited to Question three. Although the dissent argued the case should be
heard to determine whether a patent claim is invalid if it improperly
seeks to "claim a monopoly over a basic scientific relationship," the
Court held that certiorari was improvidently granted. [Summarized by
Jenny Stallard Lillge.]
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UNITED STATES SUPREME COURT NEWS Willamette Law Online Willamette University
College of Law Editor-in-Chief: Eric Leonard: eleonard@willamette.edu
To subscribe or unsubscribe, go to http://www.willamette.edu/wucl/wlo/
Note: Willamette Law Online functions as a notification service, alerting users
to legal decisions and trends, and is neither intended to be a comprehensive
resource of case law nor a substitute for in-depth legal research. The court
posts its opinions on Findlaw, thus providing the source for links to the full
text of the cases. Occasionally, these links become available online after this
service has already published its edition and cannot, therefore, be included in
the edition.
