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Stryker Corp. v. Hill-Rom Services, Inc.
United States Patent Trial and Appeal Board
2014 WL 5282150 (2014)
Hill-Rom Services, Inc. (Hill-Rom) (plaintiff) applied for a patent for a system enabling hospital workers to monitor hospital beds electronically. The inventor, Steven Dixon, was an engineer with a bachelor’s degree in electrical engineering technology, who was also knowledgeable in the field of communications. The patent examiner found that a person having ordinary skill in the art would understand the scientific and engineering principles related to the complex hospital bed system, which required knowledge of both medical systems and communication networks. On an appeal before the United States Patent Trial and Appeal Board (Board), Hill-Rom contended that the examiner did not appropriately set forth the level of ordinary skill of a person in the relevant art. In considering Hill-Rom’s argument, the Board analyzed the testimony of Michael Hayes, an employee of Stryker Corp. (Stryker) (defendant) involved in the development of networked hospital beds, who held the same degree as Dixon, and who testified regarding his knowledge about communication networks including controller area networks (CAN), a particular type of highly efficient network cited by many publications.
Rule of Law
Holding and Reasoning (Lebovitz, J.)
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