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Nautilus, Inc., v. Biosig Instruments, Inc. | 572 U.S. 898 (2014)
For the benefit of a patent holder and other inventors, a patent’s claims, which describe the protected invention, should be specific enough that the patent’s scope, or what it does and doesn’t cover, is ascertainable. In Nautilus, Incorporated versus Biosig Instruments, Incorporated, the United States Supreme Court explored how specific a patent’s claims must be for the patent to be valid.
Biosig Instruments held a patent for a heart-rate monitor used in the handlebars of exercise equipment. The patent’s claims described a cylindrical bar featuring, among other things, two electrodes on each half of the bar, mounted, quote, “in spaced relationship with each other,” unquote.
In hopes of reaching a licensing agreement, Biosig shared its patented technology with Stairmaster Sports Medical Products. Without entering an agreement, however, Stairmaster, which was later acquired by Nautilus, Incorporated, began selling machines featuring Biosig’s technology.
Biosig sued Nautilus in federal court for patent infringement. Nautilus moved for summary judgment, arguing that Biosig’s patent failed to satisfy the Patent Act’s definiteness requirement and was therefore invalid for indefiniteness. Specifically, Nautilus argued that the patent’s reference to electrodes in spaced relationship with each other lacked sufficient detail as to the placement and size of the electrodes.
The district court granted Nautilus’s motion for summary judgment, finding Biosig’s patent invalid for indefiniteness. The Federal Circuit reversed, stating that a patent claim is only indefinite if it’s not amenable to construction or is insolubly ambiguous, and Biosig’s patent claim didn’t fall into that category. The United States Supreme Court granted cert.
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