Arrhythmia Research Technology, Inc. v. Corazonix Corp. (JWB Class)

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The Case

  • Arrhythmia patented a method of detecting threatening condition in post-heart attack victims
  • District Court found the claims to be non-statutory
  • Decided by CCPA to be statutory
  • “question of law” = it is within Court’s authority to look at facts of case and determine whether it’s statutory subject matter
    • can determine if lower Court is right or wrong
    • if the case is a determination of fact, much harder for higher Court to overturn
  • Freeman-Walter-Abele – two-step process to ease decisions on section 101 cases
    • held this patent valid
  • held that these numbers (data) are not abstract – they are signals representing someone’s heart function (helps the ‘physical change’ argument)

Relevant Cases

  • Congress intended section 101 to include “anything under the sun that is made by man” (everything)
  • Gottschalk v. Benson – claims that “wholly pre-empt” a mathematical algorithm (keeps others from using the algorithm) are not patentable
  • Flook v. Parker – if the claim is directed to a new and useful process, independent of whether the algorithm used is novel
  • Diamond v. Diehr – as long as the algorithm/scientific truth is implemented into a novel and useful structure, it is patentable