Laboratory Corp. of America Holdings v. Metabolite Laboratories, Inc., 548 U.S. 124 (2006)
Primary Holding
A patent cannot claim a monopoly over a basic scientific relationship, such as the correlation between homocysteine levels and vitamin deficiencies, as this falls under the exclusion of laws of nature and natural phenomena from patent protection.
In the case of Laboratory Corp. of America Holdings v. Metabolite Laboratories, the Supreme Court decided that you can't patent a natural relationship, like how high levels of homocysteine in the blood can indicate vitamin deficiencies. This is important because it means that medical tests and knowledge about health can't be owned by one company, allowing more access to important health information for everyone. This case is relevant if you're getting tested for vitamin deficiencies or if you're involved in medical research, as it ensures that basic health knowledge remains available to all without restrictions.
AI-generated plain-language summary to help you understand this case
In Laboratory Corp. of America Holdings v. Metabolite Laboratories, Inc., the underlying dispute centers on a patent held by Metabolite Laboratories that claims a process for diagnosing deficiencies in vitamins folate and cobalamin. The patented process involves measuring the level of homocysteine in a body fluid and determining if it is elevated, which indicates a potential vitamin deficiency. Laboratory Corporation of America Holdings (LabCorp) was found liable for inducing infringement of this patent by encouraging doctors to order tests that measure homocysteine levels. The procedural history of the case began with lower courts affirming the validity of the patent and ruling against LabCorp for its role in inducing infringement. The courts imposed damages on LabCorp and issued an injunction preventing the company from using tests that could lead to the diagnosis of vitamin deficiencies based on elevated homocysteine levels. LabCorp subsequently sought a writ of certiorari from the Supreme Court to challenge the validity of the patent, arguing that it improperly claimed a monopoly over a basic scientific relationship. The case reached the Supreme Court, which ultimately dismissed the writ of certiorari as improvidently granted. This dismissal indicated that the Court would not address the substantive issues raised regarding the patent's validity. The dissenting opinion, authored by Justice Breyer and joined by Justices Stevens and Souter, expressed concern that the dismissal left important questions unanswered, particularly regarding the implications of patenting scientific relationships in the medical field.
Whether a patent claim that seeks to monopolize a basic scientific relationship, specifically the relationship between homocysteine levels and vitamin deficiencies, is invalid under the principle that laws of nature and natural phenomena are not patentable.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- Unknown
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
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