Summary
This published opinion from the United States Court of Appeals for the Fourth Circuit affirms a district court's grant of a preliminary injunction in favor of Real Time Medical Systems against PointClickCare Technologies. The underlying dispute involves PointClickCare's implementation of CAPTCHA walls and account blocks to restrict Real Time's automated data extraction from its electronic health record platform. The court reviews claims of unfair competition and tortious interference with contracts, concluding that the district court did not abuse its discretion.
Topics
Practice areas
Questions Presented
- Whether PointClickCare's use of indecipherable CAPTCHAs and blocking of Real Time's accounts constitutes information blocking under the 21st Century Cures Act.
- Whether a Maryland unfair‑competition claim may be predicated in part on a violation of a federal statute that lacks a private right of action.
- Whether the district court's preliminary injunction should be affirmed.
Holdings
- The court held that PointClickCare's practices do constitute information blocking because none of the statutory exceptions (manner, health‑IT‑performance, or security) apply.
- The court held that Real Time may rely on the Cures Act violation as evidence to support its unfair‑competition claim.
- The court affirmed the preliminary injunction, finding Real Time satisfied the four‑factor test.
Key quotations
“We have defined the status quo for this purpose to be ‘the last uncontested status between the parties which preceded the controversy.’” (at *1)
“The district court correctly noted that irreparable harm can include ‘actual and imminent’ ‘loss of good will or erosion of [a company’s] customer base.’” (at *5)
Factual background
Real Time provides health‑analytics services to skilled‑nursing facilities by automatically downloading patient data from PointClickCare's electronic health‑record system using bots. PointClickCare later introduced indecipherable CAPTCHAs and blocked Real Time's accounts, alleging security and performance concerns. Real Time sued for an injunction to stop the blocking, asserting unfair‑competition and tortious‑interference claims under Maryland law and relying on the 21st Century Cures Act's information‑blocking provisions.
Procedural history
The district court entered a preliminary injunction blocking PointClickCare's use of indecipherable CAPTCHAs and account blocking. Real Time appealed the injunction to the Fourth Circuit.