Medical Records System Patent Invalid Under 35 U.S.C. § 101

The court granted defendant's motion to dismiss because the asserted claims of plaintiff’s medical records system patent encompassed unpatentable subject matter and found that the claims were directed toward an abstract idea. "The independent claims are drawn to a system for maintaining patient records that permits tiered access, including reading and editing, by physicians and patients. . . . The 'concept of record access and management' is an abstract idea, even as applied in the particular context of medical records. . . . [Plaintiff] singles out dependent claim 14, which recites that the two-way firewall program 'includes a feature permitting the physician to override the firewall feature and permit the participating patient for a limited time to view limited portions of the physician medical record for said participating patient.' But that, too, is simply the computer-based equivalent of an age-old practice — a physician showing a patient certain test results or diagnostic notes."

Preservation Wellness Technologies, LLC v. Allscripts Healthcare Solutions, Inc., 2-15-cv-01559 (TXED May 10, 2016, Order) (Bryson, C.J.)