Rajagopal v. Brent: Federal Circuit Vacates PVC Detection Patent Board Ruling
A seven-inventor team led by Gautham Rajagopal challenged the USPTO’s Board decision on a premature ventricular contraction detection patent (US16/436012) at the Federal Circuit. The court vacated the Board’s ruling and remanded the case to the PTO in under 195 days — an unusually swift appellate resolution for a patentability dispute.
Federal Circuit Wipes PTAB Slate Clean on Cardiac PVC Patent
In case No. 24-2040, a group of seven inventors — led by Gautham Rajagopal and including Gary Toering, Jerry D. Reiland, Michael L. Hudziak, Shantanu Sarkar, Stephanie Chen, and Yuying Chao — appealed a USPTO Patent Trial and Appeal Board decision concerning patent application US16/436012 (published as US20200383597A1), which covers premature ventricular contraction (PVC) detection technology. The appeal was filed on July 2, 2024 and decided on January 13, 2025 at the Court of Appeals for the Federal Circuit.
The Federal Circuit granted the parties’ motion, vacated the Board’s patentability decision, and remanded the case to the PTO for further consideration consistent with the motion and the court’s order. Critically, the court did not rule on the merits of patentability — the vacatur means the Board’s underlying decision is nullified, and the PTO must reconsider the application afresh. Each party was ordered to bear its own litigation costs.
Resolution in 195 days is notably fast for a Federal Circuit patent appeal, suggesting the vacatur was likely driven by a joint or unopposed motion — possibly reflecting a change in law, new USPTO guidance, or a procedural deficiency identified post-briefing. The public record does not disclose the precise grounds of the motion, leaving open what specific errors the PTO must address on remand. The outcome leaves the patentability of the PVC detection application unresolved but restores the inventors’ opportunity for a fresh examination.
Filing to Vacated and Remanded in 195 days
195 days — faster than the typical Federal Circuit patent appeal, which averages 12–18 months
Federal Circuit vacates: what the remand means for both parties
Vacatur nullifies the Board’s decision without a merits ruling
When the Federal Circuit vacates a PTAB decision, it wipes the lower ruling from the books entirely — as if it never happened. Unlike a reversal (which substitutes a new outcome) or an affirmance (which confirms the ruling below), a vacatur returns the parties to an earlier procedural posture. The PTO must now reconsider the application from the point directed by the remand order, unconstrained by the Board’s vacated findings.
No merits adjudicationInventors win a second chance — but patentability remains open
The vacatur is a procedural victory for the Rajagopal inventor team: the adverse Board decision that blocked their patent is gone. However, the Federal Circuit did not hold that their claims are patentable. On remand, the PTO will re-examine the application under whatever standard or guidance the court’s order prescribes. The inventors retain the opportunity to secure patent protection for their PVC detection technology, but must still satisfy patentability requirements.
Remand opportunity preservedPTO must re-examine under fresh instructions
The USPTO, as the defending party, must now conduct further consideration of the patent application consistent with the Federal Circuit’s order. The vacatur suggests the Board’s original decision contained a procedural or substantive deficiency identified by the court or conceded via the parties’ motion. The PTO’s re-examination will be closely watched, as it effectively sets the second-chance standard for this cardiac monitoring innovation.
Re-examination requiredPVC detection IP landscape remains in flux pending remand
Until the PTO issues a new determination on remand, freedom-to-operate assessments covering US16/436012 remain uncertain. Companies developing cardiac monitoring devices, wearable ECG products, or PVC classification algorithms should monitor the remand proceedings closely. If the claims ultimately issue, they could affect a commercially active segment of the digital health and cardiac diagnostics market. The vacatur does not grant the patent — it simply reopens the examination.
FTO uncertainty continuesFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | GAUTHAM RAJAGOPAL | Individual | Seven-inventor team — applicants for PVC cardiac detection patent US16/436012Search in Eureka ↗ |
| Co-Plaintiff | GARY TOERING | Individual | Search in Eureka ↗ |
| Co-Plaintiff | JERRY D. REILAND | Individual | Search in Eureka ↗ |
| Co-Plaintiff | MICHAEL L. HUDZIAK | Individual | Search in Eureka ↗ |
| Co-Plaintiff | Shantanu Sarkar | Individual | Search in Eureka ↗ |
| Co-Plaintiff | STEPHANIE CHEN | Individual | Search in Eureka ↗ |
| Co-Plaintiff | YUYING CHAO | Individual | Search in Eureka ↗ |
| Defendant | DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark Office | Individual | Acting USPTO Director — defending PTAB’s patentability determination on remandSearch in Eureka ↗ |
| Plaintiff counsel | Naveen Modi | Attorney | Counsel for GAUTHAM RAJAGOPALSearch in Eureka ↗ |
| Plaintiff law firm | Paul Hastings, LLP | Law Firm | Representing GAUTHAM RAJAGOPALSearch in Eureka ↗ |
| Defendant counsel | Amy J. Nelson | Attorney | Counsel for DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark OfficeSearch in Eureka ↗ |
| Defendant counsel | Farheena Yasmeen Rasheed | Attorney | Counsel for DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark OfficeSearch in Eureka ↗ |
| Defendant counsel | Kakoli Caprihan | Attorney | Counsel for DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark OfficeSearch in Eureka ↗ |
| Defendant counsel | Robert Mcbride | Attorney | Counsel for DERRICK BRENT, Acting Under Secretary of Commerce for Intellectual Property and Acting Director of the United States Patent and Trademark OfficeSearch in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Court of Appeals for the Federal CircuitSearch in Eureka ↗ |
Official order — verbatim text
The Federal Circuit’s order grants the motion, vacates the Board’s decision, and remands to the PTO ‘for further consideration consistent with the motion and this order.’ This phrasing is significant: the court is not substituting its own patentability judgment — it is directing the PTO to reconsider within parameters set by the motion. The vacatur standard at the appellate level means the Board’s findings carry no precedential or res judicata weight going forward. Each side bearing its own costs suggests a consensual or unopposed resolution rather than a contested merits victory.
US16/436012 — Premature Ventricular Contraction (PVC) Detection
US16/436012, published as US20200383597A1, covers premature ventricular contraction (PVC) detection technology — a clinically significant area of cardiac diagnostics concerned with identifying abnormal heartbeats originating in the ventricles. PVCs are among the most common cardiac arrhythmias and their automated detection is a core function of modern ECG devices, wearables, and remote monitoring platforms. The application was filed by a seven-inventor team, suggesting a complex or multi-component technical contribution.
In the digital health sector, accurate PVC detection algorithms are commercially critical for device makers, software developers, and remote patient monitoring companies. A granted patent on core PVC detection methodology could create meaningful barriers for competitors in the wearable cardiac monitoring, implantable device, and AI-driven ECG analytics spaces. The Federal Circuit’s remand leaves the ultimate scope of the claims unresolved, making this a live risk factor for any company operating in automated arrhythmia detection.
Should you run an FTO against US16/436012 (PVC Detection)?
Any team developing PVC detection features — whether in wearable ECG patches, smartwatches, implantable cardiac monitors, remote patient monitoring software, or AI-driven arrhythmia classification engines — should flag US16/436012 as an active risk. The Federal Circuit vacatur has not invalidated the claims; it has returned the application to the PTO for reconsideration. Until the remand proceedings conclude, the application’s ultimate claim scope is unknown and potentially enforceable if granted.
PatSnap Eureka’s FTO Search Agent can map your product’s PVC detection methodology against the published claims and prosecution history of US20200383597A1, identify prior art the PTO may apply on remand, and flag related cardiac arrhythmia patents in the same inventor family or technology cluster. Setting a monitoring alert for the remand outcome ensures your FTO opinion stays current as the PTO’s re-examination progresses.
Run a freedom-to-operate analysis on US20200383597A1 to assess your product’s exposure
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What this case signals for the cardiac diagnostics IP landscape
A Federal Circuit vacatur on a PVC detection patent application sends a meaningful signal to digital health and cardiac monitoring innovators.
Vacaturs on motion often signal procedural defects — monitor for new USPTO guidance
When a Federal Circuit vacatur is granted on motion rather than after full merits briefing, it typically suggests a change in controlling law, new agency guidance, or an acknowledged procedural error. IP teams in cardiac diagnostics should watch the PTO’s remand proceedings in this case as a bellwether for how similar PVC detection claims will be treated.
FTO on US16/436012 remains unresolved — defer clearance opinion until remand completes
Product teams building PVC detection features into wearables, implantables, or diagnostic software cannot yet treat this application as lapsed or invalid. The vacatur preserves the inventors’ patent rights pending re-examination. Any freedom-to-operate analysis touching PVC classification methods should flag this application and schedule a review once the PTO issues its remand decision.
RAJAGOPAL v DERRICK — key questions answered
The vacatur nullifies the USPTO Board’s patentability decision on US16/436012. The Federal Circuit did not rule on whether the claims are patentable — it returned the case to the PTO for fresh consideration. The inventors’ application remains pending, and the PTO must re-examine it consistent with the court’s remand order.
Yes. A vacatur does not invalidate or abandon the patent application. US16/436012 remains active and pending before the PTO. If claims ultimately issue following the remand examination, they would be enforceable. Companies developing PVC detection products should monitor the remand proceedings and maintain an updated FTO position.
A resolution of 195 days is atypically fast for a Federal Circuit patent appeal, which typically takes 12–18 months. The speed is consistent with a grant on joint or unopposed motion, bypassing full merits briefing. This suggests the parties — or the court — identified a clear procedural or legal ground for vacatur without requiring extensive adversarial argument.
The appeal (Case No. 24-2040) was decided by the Court of Appeals for the Federal Circuit, which has exclusive jurisdiction over patent appeals from the USPTO and district courts. The case arose from a USPTO Patent Trial and Appeal Board decision on patent application US16/436012.
US16/436012 (published as US20200383597A1) covers premature ventricular contraction (PVC) detection — a method or system for automatically identifying abnormal ventricular heartbeats in cardiac rhythm data. PVC detection is commercially relevant for wearable ECG devices, implantable cardiac monitors, remote patient monitoring platforms, and AI-driven arrhythmia classification software.
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