Background
Cleveland Medical Devices Inc. (CleveMed) develops and markets diagnostic and therapeutic technology for sleep disorders, including polysomnographic monitoring systems and positive airway pressure (PAP) therapy management platforms. The company holds a portfolio of patents covering networked sleep disorder treatment systems — technologies that connect remote patients, clinicians, and equipment in integrated telemedicine workflows for managing conditions like obstructive sleep apnea.
ResMed Corp., a leading manufacturer of sleep therapy equipment and cloud-connected sleep monitoring software, filed two inter partes review (IPR) petitions challenging a pair of related CleveMed patents. IPR2025-00246 targeted U.S. Patent No. 11,857,333 (directed to an integrated sleep diagnostic and therapeutic system and method), and IPR2025-00247 targeted U.S. Patent No. 11,872,029 (directed to devices and methods for sleep disorder diagnosis and treatment). Both patents cover overlapping aspects of networked telemedicine technology for sleep disorder management. The PTAB instituted review in both proceedings, and oral arguments were held in April 2026.
The Court’s Holding
On June 30, 2026, the PTAB issued final written decisions in both IPR proceedings — yielding a split outcome. In one proceeding, the PTAB agreed with ResMed and found the challenged claims unpatentable, canceling those claims as anticipated or obvious in light of the prior art. In the companion proceeding, however, the PTAB sided with CleveMed, finding that ResMed had not met its burden of proving the challenged claims unpatentable by a preponderance of the evidence, and confirming those claims as patentable.
The split result illustrates a well-known dynamic in IPR litigation involving patent families: even closely related patents with overlapping subject matter can yield different outcomes if the specific claim language, priority dates, and prior art combinations are evaluated independently by the Board. The confirmed claims in the surviving patent will remain enforceable against ResMed and others.
Key Takeaways
- PTAB IPR challenges against patent families do not guarantee uniform outcomes — each patent’s claims must independently survive the petitioner’s prior-art case, and subtle differences in claim language can determine whether a patent lives or dies.
- The split decision means CleveMed retains enforceable IP coverage in the sleep apnea telemedicine space, even as one patent in the family was invalidated.
- For ResMed, the partial victory may limit — but not eliminate — exposure to infringement claims based on the surviving patent’s remaining claims.
- This decision adds to a growing body of PTAB outcomes in the digital health and networked medical device sector, where patent claims on telemedicine infrastructure and remote monitoring are increasingly contested.
Why It Matters
The sleep apnea device and software market is fiercely competitive, with incumbents like ResMed using both product development and patent challenges to maintain market position. PTAB inter partes review has become a standard tool for device manufacturers seeking to clear patent obstacles from competitors’ portfolios. The CleveMed split outcome is a reminder that IPR petitions — even well-constructed ones with strong prior art — can fail on individual claims if the Board finds that the petitioner’s arguments do not precisely map to the claim language at issue.
For companies managing digital health and telemedicine patent portfolios, the case also underscores the value of layered IP protection: filing overlapping patents with distinct claim trees so that invalidation of one patent does not extinguish the entire portfolio. CleveMed’s partial survival here demonstrates exactly that strategy in practice.