Baxter International, Inc. v. CareFusion Corporation et al, 1-15-cv-09986 (ILND May 13, 2016, Order) (St. Eve, J.)
Tuesday, May 17, 2016
Battery Gauge Patent Not Invalid Under 35 U.S.C. § 101
The court denied defendant's motion to dismiss on the ground that plaintiff’s infusion pump battery gauge patent encompassed unpatentable subject matter because the asserted claims were not directed toward an abstract idea. "[Defendant] first argues that the [patent-in-suit] is directed to the unpatentable abstract idea of calculating the remaining time of charge on a battery, based on well-known voltage and current measurements. . . . [Defendant] identifies no precedent entitling a court to limit its Section 101 analysis to 'novel' features while ignoring the tangible components of a claimed patent. . . . Viewing the [patent] as a whole, the Court finds that its claims are not directed to abstract ideas. The claims of the [patent] are directed to a concrete, tangible instrument that utilizes a sampling detection technique, measuring battery voltage and current drain, to determine the time of remaining battery life and to issue applicable alert messages. . . . The use of a microprocessor, moreover, to calculate 'the amount of time left under battery power,' does not itself render the [patent] an abstract idea, particularly where [defendant] points to no evidence that the human mind could perform such calculation entirely on its own."