ResMed v. Cleveland Medical Devices: CPAP Patent Case Stayed After 637 Days
ResMed filed suit against Cleveland Medical Devices in the Northern District of Ohio asserting US11602284B1 across its flagship AirSense, AirCurve, AirMini, and Astral device lines. After 637 days of litigation, Judge Brennan stayed the case pending USPTO proceedings and removed it from the active docket, with a 30-day reopen window once those proceedings become final.
ResMed’s PAP Device Patent Dispute Paused at USPTO Crossroads
ResMed Co. filed this infringement action on November 16, 2023 in the Northern District of Ohio against Cleveland Medical Devices Inc., asserting patent US11602284B1, which covers technology central to positive airway pressure therapy systems. The accused products span ResMed’s most commercially significant device lines, including the AirSense 10 and 11 CPAP families, AirCurve 10 series, AirMini CPAP and its companion app, Astral and Stellar ventilators, and the myAir and AirView connected-care platforms — effectively the full breadth of ResMed’s sleep and respiratory therapy portfolio.
The case did not reach a merits verdict. On August 14, 2025, Judge Bridget Meehan Brennan entered an order removing the case from the active docket following a previously entered stay tied to USPTO proceedings concerning the asserted patent. The stay mechanism is procedurally significant: it is not a dismissal, and the underlying claims remain live. Plaintiff’s counsel must move to reopen within 30 days of the USPTO proceedings becoming final, or risk denial of that motion and outright dismissal of the action.
The 637-day duration before the stay order reflects the maturity this litigation reached before inter partes or ex parte USPTO proceedings apparently introduced threshold validity questions. The public record does not confirm the specific type of USPTO proceeding — IPR, ex parte reexamination, or otherwise — that triggered the stay, nor does it disclose the substantive positions of either party. The outcome of those proceedings will be determinative: a final USPTO decision unfavorable to ResMed could significantly narrow or extinguish the asserted claims, while a favorable outcome would likely prompt ResMed to seek rapid reinstatement.
Filing to Case Stayed in 637 days
637 days litigated before USPTO stay — above median for stayed patent cases
Case stayed pending USPTO: what the docket removal means for both parties
A stay is not a dismissal — claims remain live
Removing a case from the active docket following a stay order is a housekeeping measure, not a merits ruling. The asserted patent claims and infringement allegations remain legally intact. The Court’s order specifically preserves ResMed’s right to reopen within 30 days of USPTO finality, meaning the litigation clock is paused, not stopped. This structure is consistent with courts managing docket efficiency while deferring to USPTO expertise on patent validity.
Stay — no merits rulingResMed’s enforcement window hinges on USPTO outcome
ResMed retains the right to reinstate its infringement claims but must act within a strict 30-day window after USPTO proceedings conclude. A favorable USPTO outcome — such as surviving IPR or reexamination with claims intact — would allow ResMed to press its case against Cleveland Medical’s competing products. Failure to monitor the USPTO docket and timely move to reopen risks losing the litigation position built over 637 days of pre-stay proceedings.
Conditional reinstatement rightCleveland Medical’s USPTO strategy now carries litigation weight
For Cleveland Medical Devices, the USPTO proceedings represent a potentially decisive front. If the asserted claims of US11602284B1 are cancelled or materially narrowed, the infringement case may collapse or be substantially weakened before it returns to court. The stay effectively rewards any successful USPTO challenge Cleveland Medical has initiated or joined. Until the USPTO issues a final decision, Cleveland Medical operates under continued uncertainty regarding its PAP-related products.
USPTO challenge is key defense leverPAP device market IP risk remains elevated during stay
The breadth of accused products — spanning CPAP, APAP, bilevel, and ventilator categories along with connected-care software — signals that US11602284B1 is asserted as a foundational portfolio patent. Competitors and OEM partners in the PAP therapy space should monitor the USPTO proceedings closely, as the claim scope surviving those proceedings will define the enforceability perimeter for this patent across the sector. A broad claim survival would strengthen ResMed’s licensing and enforcement leverage industry-wide.
Watch USPTO — sector-wide impactFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | Resmed, Co. | Company | Global sleep and respiratory therapy company — holder of US11602284B1Search in Eureka ↗ |
| Defendant | Cleveland Medical Devices, Inc. | Company | Cleveland-based medical device developer focused on sleep diagnostics and therapySearch in Eureka ↗ |
| Plaintiff counsel | Angela C. Whitesell | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff counsel | Brian Biggs | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff counsel | David R. Knudson | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff counsel | Elise K. Yarnell | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff counsel | Matthew S. Middleton | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff counsel | Michael R. Reed | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff counsel | Nancy Braman | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff counsel | Sean C. Cunningham | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff counsel | Tiffany C. Miller | Attorney | Counsel for Resmed, Co.Search in Eureka ↗ |
| Plaintiff law firm | Carpenter Lipps – Columbus | Law Firm | Representing Resmed, Co.Search in Eureka ↗ |
| Plaintiff law firm | DLA Piper US LLP | Law Firm | Representing Resmed, Co.Search in Eureka ↗ |
| Plaintiff law firm | DLA Piper – San Diego | Law Firm | Representing Resmed, Co.Search in Eureka ↗ |
| Plaintiff law firm | DLA Piper – Wilmington | Law Firm | Representing Resmed, Co.Search in Eureka ↗ |
| Plaintiff law firm | Hahn Loeser & Parks (Columbus) | Law Firm | Representing Resmed, Co.Search in Eureka ↗ |
| Defendant counsel | Benu Wells | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Charles Keller | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | James R. Hannah | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Jennifer L. Gilbert | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Joshua A. Friedman | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Lisa Kobialka | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Melissa T.G. Brenner | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Michael H. Lee | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Paul J. Andre | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Sabah S. Khokhar | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant counsel | Timothy J. Layden | Attorney | Counsel for Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant law firm | Calfee, Halter & Griswold LLP (Cleveland) | Law Firm | Representing Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant law firm | Herbert Smith Freehills Kramer – New York | Law Firm | Representing Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant law firm | Herbert Smith Freehills Kramer – Redwood Shores | Law Firm | Representing Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Defendant law firm | Kramer Levin Naftalis & Frankel (Redwood Shores) | Law Firm | Representing Cleveland Medical Devices, Inc.Search in Eureka ↗ |
| Presiding judge | Judge Bridget Meehan Brennan | Judge | Ohio Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s August 14, 2025 order is procedural rather than substantive: it reflects the court’s exercise of docket management discretion following an earlier stay tied to pending USPTO proceedings. No validity or infringement determination has been made. The order’s conditional language — requiring plaintiff to move to reopen within 30 days of USPTO finality or face potential dismissal — functions as a built-in case management deadline. For both parties, the operative question is now the scope and outcome of the USPTO proceedings, which the public record does not specify.
US11602284B1 — PAP therapy device systems and connected care
US11602284B1 is a US utility patent (application number US17/825266) asserted by ResMed across its full PAP therapy device portfolio. The patent covers technology relevant to positive airway pressure systems — the class of devices used to treat obstructive sleep apnea and respiratory insufficiency. Its assertion against CPAP, APAP, bilevel, and ventilator products, as well as companion apps and cloud-monitoring platforms, suggests it protects either core therapy delivery mechanisms, adaptive algorithm features, or integrated device-software architectures — though the specific claim language is not disclosed in the public case record.
Strategically, US11602284B1 appears to function as a portfolio anchor patent for ResMed in the PAP therapy space. Asserting it against both hardware (AirSense, AirCurve, Astral, Stellar) and software platforms (myAir, AirView, AirMini App) suggests ResMed views this patent as covering a cross-stack therapy architecture. For competitors and new entrants in the sleep therapy, home ventilation, or connected respiratory care sectors, this patent represents a significant freedom-to-operate risk — particularly if its claims survive the ongoing USPTO proceedings intact.
Should you run an FTO analysis against US11602284B1?
Any company developing or commercialising CPAP, APAP, bilevel PAP, or ventilator devices — or software platforms integrated with PAP therapy hardware — should assess exposure to US11602284B1. ResMed’s decision to assert this patent across hardware, firmware, and app-based products in a single infringement action signals broad claim scope. OEMs, white-label manufacturers, and digital health companies building connected respiratory therapy solutions are among those most likely to benefit from a formal FTO review.
PatSnap Eureka’s FTO Search Agent can map the claim landscape of US11602284B1 against your product architecture, identify prosecution history disclaimers that may narrow scope, and surface prior art that may be relevant to the ongoing USPTO proceedings. With litigation paused but not resolved, this is the optimal window to conduct a proactive FTO assessment before the case returns to active status.
Run a freedom-to-operate analysis on US11602284B1 to assess your product’s exposure
Run FTO in Eureka →Similar PAP therapy and sleep tech patent cases in US district courts
Related infringement actions involving CPAP, APAP, and sleep therapy device patents litigated in US district courts, including N.D. Ohio proceedings.
What this case signals for the PAP therapy and sleep tech IP landscape
A stayed infringement action over core PAP device technology keeps competitive pressure alive while USPTO proceedings determine the patent’s enforceability.
USPTO proceedings now control the litigation trajectory for both parties
With the district court case removed from the active docket, the center of gravity has shifted entirely to the USPTO. Companies with PAP device portfolios should treat the outcome of those proceedings as a leading indicator of infringement risk across the sector — not just for Cleveland Medical. Monitoring US11602284B1 at the USPTO is now a competitive intelligence priority.
Broad accused product scope signals ResMed’s intent to protect platform-level IP
Naming AirSense, AirCurve, AirMini, Astral, Stellar, myAir, and AirView as accused products suggests ResMed views US11602284B1 as foundational — not product-specific. This enforcement posture is consistent with asserting platform-level claims that cover integrated PAP therapy and connected-care ecosystems, raising the bar for freedom-to-operate across the CPAP and respiratory device market.
Resmed v Cleveland — key questions answered
As of August 14, 2025, the case has been removed from the active docket by Judge Bridget Meehan Brennan following a stay pending USPTO proceedings related to the asserted patent, US11602284B1. The case is not dismissed — ResMed’s counsel must move to reopen within 30 days of the USPTO proceedings becoming final.
ResMed asserted US11602284B1 (application number US17/825266), a US utility patent covering technology relevant to positive airway pressure therapy devices and connected-care platforms. The accused products include the AirSense 10 and 11, AirCurve 10, AirMini, Astral, and Stellar device lines, along with myAir, AirView, and the AirMini App.
The court previously entered an order staying the litigation pending the conclusion of USPTO proceedings related to the patents at issue. The nature of those proceedings — whether IPR, ex parte reexamination, or another inter partes mechanism — is not specified in the public case record. The stay reflects standard judicial practice of deferring to USPTO expertise on patent validity questions before proceeding to trial.
If the USPTO cancels or materially narrows the asserted claims, ResMed’s infringement case would be significantly weakened or potentially moot. The court’s order allows ResMed to move to reopen within 30 days of USPTO finality, but if the patent claims no longer support the infringement allegations, the case would likely be dismissed or significantly narrowed before reaching trial.
ResMed accused a broad range of its own commercialised products of being relevant to the patent scope in the context of Cleveland Medical’s alleged infringement: AirSense 10 (CPAP, Elite, AutoSet, AutoSet for Her), AirSense 11 (CPAP, Elite, AutoSet), AirCurve 10 (S, ST, VAuto, ASV), AirMini CPAP and AirMini App, Astral 100/150 and Stellar 100/150 ventilators, AirView, and the myAir App.
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