Eli Lilly and Company v. Medtronic, Inc. — Quick Summary

Eli Lilly and Company v. Medtronic, Inc.

496 U.S. 661 (1990)

In Brief

Eli Lilly and Company v. Medtronic, Inc.

Key Issue

Does the 'safe harbor' provision of 35 U.S.C. § 271(e)(1) apply to the development and submission of information to the FDA for medical devices?

The Rule

The 'safe harbor' provision of 35 U.S.C. § 271(e)(1) permits the use of patented inventions in developing information for regulatory approval processes, extending protection not only to drug products but also potentially to medical devices.

Bottom Line

The Supreme Court held that the 'safe harbor' provision does apply to the development and submission of information to the FDA related to medical devices, thereby protecting Medtronic's activities from claims of patent infringement.

Why It Matters

Eli Lilly and Company v. Medtronic serves as a critical precedent for patent law, especially in how regulatory frameworks interact with patent rights. The case expanded the scope of the 'safe harbor' provision, clarifying its application beyond pharmaceuticals to include medical devices. This interpretation was crucial in shaping future litigation and legislative strategies for industries regulated by the FDA, such as biotechnology and health care. It underscores the importance of understanding legislative intent and statutory interpretations when dealing with regulations and patent rights.

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