Shearman & Sterling represented WebMD Health Corp. (WebMD) in its winning defense against a patent infringement suit brought by MyMedicalRecords, Inc. (MMR), a California-based firm offering online personal health records management for consumers. In summary, the Court has found all the asserted claims of both MMR patents to be invalid.

In October 2013, MMR filed a complaint against WebMD in the United States District Court for the Central District of California. The complaint alleged infringement of two patents, US Patent Nos. 8,301,466 (“the ‘466 patent”) and 8,498,883 (“the ‘883 patent”), relating to systems and methods for online management of medical records and prescriptions. MMR alleged that WebMD infringed the claimed methods through its operation of the WebMD.com website and various other online applications.

On December 23, 2014, in response to Defendants Motion for Judgment on the Pleadings, the Court issued its ruling that the asserted claims of the ‘466 patent were invalid as being directed at patent-ineligible subject matter under Section 101 of the Patent Act. The Court found that the concept of secure record access and management in the context of personal medical health records is an “age-old idea” and that patent claims covering such an abstract concept would threaten to preempt the entire field of secure filing systems. In addition, the Court stated that the ‘466 patent merely combines this abstract idea with the “routine and conventional use of the Internet and computer with no additional features.”

Further, the Court, in response to Defendants Motion for Summary Judgment, issued an Order finding every asserted claim of the ‘883 patent invalid as indefinite under Section 112 of the Patent Act.