MAYO COLLABORATIVE SERVICES V. PROMETHEUS LABORATORIES, INC.
132 S.Ct. 1289 (2012)
NATURE OF THE CASE: Mayo (D) appealed a reversal of a lower court decision that stated
Pronetheus's (P) patents claimed natural phenomena that could not be patented.
FACTS: P filed two patents which described test results used to determine if the drug the
dosage of thiopurine was high or low for a particular patient. P is the sole and exclusive
licensee of the patents. It sells diagnostic tests that embody the processes the patents
describe. Mayo (D) bought and used those tests. In 2004 D announced that it intended to
begin using and selling its own test. P sued D for patent infringement. The District Court
ultimately granted summary judgment in D's favor. The court reasoned that the patents
effectively claim natural laws or natural phenomena-namely the correlations between
thiopurine metabolite levels and the toxicity and efficacy of thiopurine drug dosages-and so
are not patentable. The Federal Circuit reversed. It pointed out that in addition to these
natural correlations, the claimed processes specify the steps of (1) 'administering a
[thiopurine] drug' to a patient and (2) 'determining the [resulting metabolite] level.'
These steps, it explained, involve the transformation of the human body or of blood taken
from the body. Thus, the patents satisfied the Circuit's 'machine or transformation test,'
which the court thought sufficient to 'confine the patent monopoly within rather definite
bounds.' The Supreme Court granted certiorari.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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