Ariosa Diagnostics, Inc. v. Sequenom, Inc.

788 F.3d 1371 (2015)

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Ariosa Diagnostics, Inc. v. Sequenom, Inc.

United States Court of Appeals for the Federal Circuit
788 F.3d 1371 (2015)

Facts

Dennis Lo and James Wainscoat discovered cell-free fetal DNA (cffDNA) in maternal blood samples that researchers had previously treated as medical waste. Lo and Wainscoat were then able to isolate paternally inherited cffDNA, from which certain fetal characteristics could be determined. Lo and Wainscoat obtained a patent (the ‘540 patent) on the process of amplifying and detecting cffDNA. Sequenom, Inc. (defendant) was licensed to commercialize the invention by selling prenatal tests. Sequenom sent letters to companies that sold similar tests, accusing them of patent infringement. One of those companies, Ariosa Diagnostics, Inc. (Ariosa) (plaintiff), sought a declaratory judgment of noninfringement in federal district court. The court found that the ‘540 patent was invalid on the ground that paternal cffDNA was a naturally occurring phenomenon to which Lo and Wainscott failed to make sufficient inventive additions. Sequenom appealed to the United States Court of Appeals for the Federal Circuit.

Rule of Law

Issue

Holding and Reasoning (Reyna, J.)

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