Stryker Corp. v. Hill-Rom Services, Inc.
United States Patent Trial and Appeal Board
2014 WL 5282150 (2014)
Hill-Rom Services, Inc. (plaintiff) applied for a patent covering a system letting hospital workers electronically monitor hospital beds, invented by engineer Steven Dixon, who held a bachelor's degree in electrical engineering technology and communications expertise. The patent examiner found that a person of ordinary skill in this art would need to understand both medical systems and communication networks; on appeal, Hill-Rom argued the examiner hadn't properly established the relevant skill level, and the Board considered testimony from Stryker Corp. (defendant) employee Michael Hayes, who held the same engineering degree as Dixon and testified about controller area networks (CAN), a highly efficient network type referenced in numerous relevant publications.
Whether, in determining the level of ordinary skill in the art pertaining to a patent, the factfinder may consider factors including the field of the invention, the nature of the problems in the particular art, and the level of education of the inventor and active workers in the field.