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Cardiac Pacemakers, Inc. v. Coratomic, Inc.

Citations: 702 F.2d 671; 218 U.S.P.Q. (BNA) 115; 1983 U.S. App. LEXIS 31337Docket: 82-1513

Court: Court of Appeals for the Eighth Circuit; January 17, 1983; Federal Appellate Court

Narrative Opinion Summary

This case involves a declaratory judgment action initiated by Cardiac Pacemakers, Inc. (CPI) against Coratomic, Inc. concerning the validity and potential infringement of three patents related to heart pacemakers. The District Court declared the patents invalid due to obviousness, with the design patent additionally invalidated for being functionally dictated, and ruled no infringement by CPI. The Eighth Circuit affirmed these findings, noting no clear error in the District Court's factual assessments and emphasizing the patents' obviousness to those skilled in the art, thereby sidestepping the infringement issue. Coratomic's challenge to personal jurisdiction was dismissed, as the courts found sufficient business contacts in Minnesota under the state's long-arm statute, compliant with due process. Additionally, the appellate court sustained the lower court's decision to strike Coratomic's jury demand concerning its Microthin pacemakers, citing no new substantive issues in the amended counterclaim. The judgment was affirmed without further elaboration, indicating the straightforward application of established legal principles without broad precedential impact.

Legal Issues Addressed

Design Patent Invalidity Due to Functional Considerations

Application: The design patent was invalidated because its design was primarily dictated by functional considerations.

Reasoning: The District Court ruled that...the design patent was also invalid because its design was primarily dictated by functional considerations.

Non-infringement of Patents

Application: The District Court found that CPI's products did not infringe on any of the patents held by Coratomic.

Reasoning: Additionally, the court found that none of the patents was infringed by CPI's products.

Patent Invalidity Due to Obviousness

Application: The District Court held that the patents in question were invalid due to obviousness, a ruling which was affirmed by the Eighth Circuit.

Reasoning: The Eighth Circuit affirmed the District Court's ruling on the patents' invalidity, finding no clear error in the factual determinations regarding obviousness.

Personal Jurisdiction Under Long-Arm Statute

Application: The court determined that Coratomic had sufficient business contacts in Minnesota to establish personal jurisdiction under the state's long-arm statute without violating the Due Process Clause.

Reasoning: Coratomic's argument for lack of personal jurisdiction was rejected...sufficient business contacts in Minnesota to establish jurisdiction under the state's long-arm statute, which did not violate the Due Process Clause.

Striking of Jury Demand

Application: The appellate court upheld the decision to strike Coratomic's jury demand, finding no new substantive issues were introduced in the amended counterclaim regarding the Microthin line.

Reasoning: The appellate court upheld the lower court's ruling, noting that the amended counterclaim did not introduce new substantive issues and that evidence regarding the Microthin line was admissible under the original pleadings.