The Court of Appeals for the Federal Circuit held that the claims drawn to a device that more accurately distinguishes atrial fibrillation and atrial flutter from other types of arrythmias are directed to patent eligible improvement under 35 U.S.C. § 101.
The Federal Circuit stated that the claimed invention achieves multiple technological improvements by identifying “variability in the beat-to-beat timing . . . as relevant to the at least one of atrial fibrillation and atrial flutter in light of the variability in the beat-to-beat timing caused by ventricular beats identified by the ventricular beat detector," as confirmed in the written description.
The Federal Circuit also added that "step one of the Alice framework does not require an evaluation of the prior art or facts outside of the intrinsic record regarding the state of the art at the time of the invention."
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