Linden v. ResMed, Inc.

Linden v. ResMed, Inc. The Federal Circuit affirmed the Rule 12(b)(6) dismissal with prejudice, holding that representative claim 1 of the '150 patent is directed to the abstract idea of a remote version of an in-person doctor visit and lacks an inventive concept. Linden's challenge to the choice of claim 1 as representative was waived. The decision shows that telehealth-style claims reciting generic networked devices remain vulnerable to early § 101 dismissal, and that conclusory 'not routine' allegations in an amended complaint will not create a Berkheimer-type fact dispute. Affirmed. Linden sued ResMed on the '150 patent (powered physical displays on mobile devices). The district court dismissed under § 101 with leave to amend, then dismissed the First Amended Complaint with prejudice, treating claim 1 as representative. Representative claim: Linden's counsel told the district court claim 1 was representative and both complaints called it exemplary, so the appellate challenge was waived. Step one: claim 1 is a remote version of an in-person doctor visit, a conventional organized human activity. It recites only generic hardware (an internet-capable device with a display and input transducer, and an unspecified second device), and Linden identified no improvement to computer technology under Enfish. Step two: the claimed ordered combination merely restates the abstract idea, which cannot supply the inventive concept. The FAC's allegations were conclusory or lacked technical detail, and Linden's 'device-level control' and 'therapeutic execution' arguments rest on unclaimed features. § 101 waiver / forfeiture non-precedential § 101 waiver / forfeiture non-precedential § 101 waiver / forfeiture