Mayo Collaborative Services v. Prometheus Laboratories, Inc.

 
DOCKET NO.
OP. BELOW
SUBJECT
Patent
AUTHOR
Breyer

Question(s) Presented

“The case before us . . . . concerns patent claims covering processes that help doctors who use thiopurine drugs to treat patients with autoimmune diseases determine whether a given dosage level is too low or too high. The claims purport to apply natural laws describing the relationships between the concentration in the blood of certain thiopurine metabolites and the likelihood that the drug dosage will be ineffective or induce harmful side-effects. We must determine whether the claimed processes have transformed these unpatentable natural laws into patent-eligible applications of those laws.”

Holding

“We conclude that they have not done so and that therefore the processes are not patentable. . . . In particular, the steps in the claimed processes (apart from the natural laws themselves) involve well-understood, routine, conventional activity previously engaged in by researchers in the field. At the same time, upholding the patents would risk disproportionately tying up the use of the underlying natural laws, inhibiting their use in the making of further discoveries.”