Laboratory Corporation of America Holdings v. Metabolite Laboratories, Inc.

Three university doctors discovered a correlation between elevated homocysteine levels and folic acid/vitamin B12 deficiency and patented the correlative process, which was licensed to Metabolite Laboratories (plaintiff) and then sublicensed to Laboratory Corporation of America Holdings (LabCorp) (defendant) in exchange for a share of revenue, with a clause letting LabCorp terminate if a more cost-effective alternative test emerged. When other companies, including Abbott Laboratories, developed a similar correlative test, LabCorp began using an alternative method, prompting Metabolite to sue for patent infringement and breach of the license agreement, arguing its patent covered any doctor-ordered test correlating homocysteine levels with vitamin deficiency. The district court found LabCorp liable, awarded damages, and enjoined it from performing any homocysteine-only test including via the Abbott method; the court of appeals affirmed, and the Supreme Court granted certiorari but ultimately dismissed the case as improvidently granted, with Justice Breyer dissenting from that dismissal.