LabCorp v. Metabolite, Inc
LabCorp v. Metabolite, Inc. is a court case related to the patentability of scientific principles which the U.S. Supreme Court agreed to hear, and later dismissed, in 2006.
In 1999, Metabolite sued LabCorp for infringement of a patent covering a diagnostic test. The claims of Metabolite's patent include the correlation between levels of homocysteine and vitamins B6 and B12. A jury ordered LabCorp to pay $4.7 million in damages and the decision was upheld by a federal court, which further stated that doctors were 'directly infringing' Metabolite's patents each time such a test is ordered and interpreted. LabCorp argued that the correlation is a principle of nature, and therefore the patent should never have been granted. The court dismissed the case, although Justice Breyer, Justice Stevens, and Justice Souter dissented from this decision. Breyer's dissenting opinion cited numerous cases in which scientific and mathematical principles had been held to be patent ineligible, including O'Reilly v. Morse and Gottschalk v. Benson..
Had the case been heard, and had Metabolite's patent been invalidated, the case would have had broad implications for biotechnology companies, which may have extended far beyond patentability of correlations of biomarkers to disease states. Lori Andrews outlined various concerns regarding how routine academic practices might become actionable under the results of the case. Metabolite's brief to the court suggested that overturning the patent might lead to invalidation of all drug patents on the grounds that the inventors "merely discovered that certain chemicals interact with the human body in ways directed by chemistry."
In Mayo v. Prometheus in 2012 the Supreme Court unanimously held what the dissenting Justices argued for in this case. That did not lead, however, to invalidation of all drug patents on the grounds that the inventors "merely discovered that certain chemicals interact with the human body in ways directed by chemistry," at least not as of 2015.
- Andrews LB (2006) The patent office as thought police, CHE 52(24), B20.
- U.S. Patent 4,940,658, the disputed patent
- LABORATORY CORPORATION OF AMERICA HOLDINGS, DBA LABCORP, PETITIONER v. METABO LITE LABORATORIES, INC., ET AL.
- Kinitsch E, et al. What Good Is a Patent?. Science.311:5763-946. doi:10.1126/science.311.5763.946
- Mayo v. Prometheus
- Diamond v. Diehr
- Diamond v. Chakrabarty
- Parker v. Flook
- O'Reilly v. Morse
- Funk Brothers Seed Co. v. Kalo Inoculant Co.
- Medical technologist
- Valid claim
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