Labcorp v. Metabolite
Metabolite sued LabCorp for patent infringement. In 1986 UPI filed a patent on a method for testing homocysteine levels in body fluids and specifically sought to protect the scientific connection between homocysteine levels and vitamin deficiency. B vitamins help metabolize homocysteine, which is an amino acid. UPI's patent describes a two-step process of testing for homocystine (an amino acid), and then correlating the level with the B vitamin levels in the body. UPI licensed Metabolite, which sublicensed Laboratory Corporation of America Holdings (LabCorp), to use the patent. From 1992-1998, LabCorp paid LabCorp paid Metabolite a royalty every time it supplied a doctor with a homocysteine test. After 1998, LabCorp began using a test developed by another company and Metabolite sued LabCorp for patent infringement.
After a trial, a jury found that the patent was valid and that LabCorp had willfully infringed Metabolite's patent, justifying enhanced damages. The United States Court of Appeals for the Federal Circuit affirmed. The Supreme Court granted certiorari only to resolve the question of whether the patent was valid since it involves detecting a natural correlation between homocysteine and vitamin B, and “laws of nature, natural phenomena, and abstract ideas” are not patentable.
Question Presented:
Whether a patent instructing a party to "correlate test results" can validly claim a monopoly over a basic scientific relationship used in medical
treatment such that a doctor infringes the patent by looking at a test result and thinking about that relationship?
