Case Summary: SmartGene v. Advanced Biological Labs

March 10th, 2014

In this new series, MMM attorney Shannon McNulty presents key information on noteworthy cases that have made, or could potentially make, a large impact on the current legal landscape.

Smartgene, Inc. v. Advanced Biological Labs

SmartGene, Inc. v. Advanced Biological Labs.,  No. 2013-1186, 2014 WL 259824, at *1-6 (Fed. Cir. Jan. 24, 2014)

The United States Court of Appeals for the Federal Circuit reaffirmed its ruling in CLS Bank Int’l v. Alice Corp. Pty that certain mental processes are not eligible for patent protection.  At issue was a patent claim for a method of determining medical treatments in which patient information was entered into a computer and the computer generated a ranked list of treatments based on this.  The Court stated that this method used a computer for the basic function of implementing a mental process so that it was not eligible for patent protection.  Court opinion available here.


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