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Supreme Court dismisses landmark patent caseJune 22, 2006

Laboratory Corporation of America (‘LabCorp’) filed an appeal against Metabolite Laboratories (‘Metabolite’). Patent holders and attorneys have been anxiously awaiting the ruling on this case. This legal dispute began when a jury trial at the District Court resulted in a verdict against LabCorp for patent infringement. LabCorp appealed to the Federal Circuit which subsequently upheld the District Court’s decision.LabCorp argued that the patent was too vague, specifically since it covered claims for a basic scientific relationship. The patent claims included a system to diagnose vitamin B12 deficiency through correlation to elevated levels of homocysteine. LabCorp alleged that each time a physician looked at a patient’s homocysteine level infringement took place. The Supreme Court dismissed the pending appeal as improvidently granted. Many had speculated that the Court’s ruling would have resulted in potentially significant changes in regards to the limits of patentable subject matter. By dismissing the case, the Supreme Court declined to enter any ruling on the merits of the case. The Court stated that the appeal was mistakenly granted. No additional explanation was provided. Justices Stephen Breyer, John Paul Stevens, and David Souter dissented from the decision to dismiss the case and stated that the patent should have been held invalid. The dissenting Justices stated that the patent’s process claim for the correlation between homocysteine and a vitamin deficiency is clearly a natural phenomenon, and therefore unpatentable.Justice Stephen Breyer wrote on behalf of the dissenters stating that the patent was ‘no more than an instruction to read some numbers in light of medical knowledge.’ Justice Breyer believes that the dismissal of this case ‘threatens to leave the medical profession subject to the restrictions imposed by this individual patent and others of its kind.’

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