CAFC Holds Medical Device Claims Patent Eligible in CardioNet v. InfoBionic

In CardioNet, LLC v. InfoBionic, Inc., No. 2019-1149 (Fed. Cir. Apr. 17, 2020), the Federal Circuit reversed the district court’s determination that the claims covering a device for monitoring electrical activity in the heart to detect the presence of atrial fibrillation were patent ineligible under 35 U.S.C. § 101. The Court explained that the claims were not directed to an abstract idea, but instead a patent-eligible improvement to cardiac monitoring technology. The Court cautioned against oversimplifying the claims and clarified that the Alice step one inquiry can be resolved at the Rule 12(b)(6) stage without looking outside the intrinsic evidence. Judge Dyk dissented-in-part, arguing that the majority improperly assessed the role of extrinsic evidence in the patent-eligibility analysis. Further discussion of the decision can be found on Finnegan’s Federal Circuit IP Blog.