Linden v. ResMed Inc.
3:24-cv-01291
| S.D. Cal. | Jun 30, 2025Background
- Plaintiff Craig L. Linden sued ResMed, Inc. and affiliates, alleging infringement of U.S. Patent No. 9,639,150 concerning remote interactive medical devices.
- The patent's main claim centers on methods of remote diagnosis and treatment using networked physical display devices to interact with patients.
- Defendants moved to dismiss the complaint under Rule 12(b)(6) for failure to state a claim, specifically challenging patent eligibility under 35 U.S.C. § 101.
- Both parties focused on Claim 1 as the representative claim for patent eligibility analysis.
- The Court evaluated the claim under the two-step Alice/Mayo framework, which addresses whether a claim is directed to an abstract idea and, if so, whether it contains an "inventive concept."
- The Court ultimately granted the motion to dismiss but allowed the plaintiff leave to amend the complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Patent eligibility under §101 (Alice Step 1) | The claim is specific, involving a unique physical display output and ordered steps; not an abstract idea | Claim is directed to abstract idea of remote diagnosis/treatment using generic tech | Claim is abstract, similar to prior cases on telehealth |
| Existence of an "inventive concept" (Alice Step 2) | Novelty lies in powered interactive display; non-generic, specific combination | No technological improvement; uses generic components; not novel | No inventive concept present; generic tech, no new solution |
| Sufficiency of factual record for eligibility | Needs factual development to counter abstractness determination | No additional facts needed, plain from patent/specification | No further record needed; legal conclusion proper |
| Leave to amend complaint | Requests leave to clarify non-conventional and novel details | Amendment futile, no facts make claim patent-eligible | Leave to amend granted due to procedural liberality |
Key Cases Cited
- Alice Corp. Pty. v. CLS Bank Int’l, 573 U.S. 208 (Supreme Court's two-step test for patent eligibility of abstract ideas)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standard for motions to dismiss)
- Mayo Collaborative Servs. v. Prometheus Lab’ys, Inc., 566 U.S. 66 (patent-eligibility exceptions for laws of nature, natural phenomena, ideas)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading requirements; conclusory allegations are insufficient)
- Aatrix Software, Inc. v. Green Shades Software, 882 F.3d 1121 (eligibility may involve factual questions at 12(b)(6) stage)
- Affinity Labs of Tex., LLC v. DIRECTV, LLC, 838 F.3d 1253 (claims’ character as a whole for Alice Step 1)
- Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (comparison to precedent for abstract ideas under Alice)
- Simio, LLC v. FlexSim Software Prods., Inc., 983 F.3d 1353 (focus on claimed advance over prior art for Alice analysis)