Medgraph, Inc. v. Medtronic, Inc.

Medgraph’s patents are directed to a method for improving and facilitating diagnosis and treatment of patients: data relating to “medically important variable[s],” such as blood sugar levels, measured from a patient’s body, are uploaded and transmitted to a central storage device, from which they can be accessed remotely by medical professionals. Medtronic manufactures and markets integrated diabetes management solutions, allowing patients to upload data relating to their diabetes, including blood glucose readings, to Medtronic’s server; patients can keep an online record and share the information remotely with a healthcare provider. Medgraph sued, alleging infringement. A year later, the Federal Circuit issued the first of its “Akamai” holdings, which culminated with a remand by the Supreme Court in 2014. The district court subsequently entered summary judgment of no infringement in favor of Medtronic, applying the law on direct infringement liability as it then stood, stating that “more than one person, i.e., the patient or doctor, neither of whom is an agent of or under contractual obligation to Medtronic, is required to perform all of the steps of the method claims.” The Federal Circuit then issued Akamai V, an en banc holding that attribution is proper “when an alleged infringer conditions participation in an activity or receipt of a benefit upon performance of a step or steps of a patented method and establishes the manner or timing of that performance.” The Federal Circuit affirmed, finding the decision unaffected by Akamai V. View "Medgraph, Inc. v. Medtronic, Inc." on Justia Law