Narrative Opinion Summary
The case involves a patent infringement dispute between Abiomed, Inc. and Maquet Cardiovascular, LLC, centering on six patents related to guidable intravascular blood pumps. Abiomed seeks a declaratory judgment of non-infringement and invalidity, challenging the patent claims and their constructions. The court conducted a Markman hearing to address disputed claim terms, focusing on whether terms should be given their ordinary meanings or if additional limitations apply based on the patent specifications and prosecution history. Key issues include the interpretation of terms under means-plus-function analysis, the application of prosecution history disclaimers, and the enablement and written description requirements under 35 U.S.C. § 112. The court's analysis emphasizes the importance of ordinary meaning unless clear disclaimers or redefinitions are present and evaluates the scope of terms in light of intrinsic evidence. The outcome remains contingent on further proceedings and factual determinations related to claim scope and potential invalidity.
Legal Issues Addressed
Claim Construction in Patent Disputessubscribe to see similar legal issues
Application: The court must interpret disputed claim terms based on their ordinary and customary meanings as understood by a person of ordinary skill in the art, unless the patentee clearly redefines the terms.
Reasoning: Claim terms should have their 'ordinary and customary meaning' as understood by someone skilled in the field, and a patentee must clearly express intent to redefine a term, rather than merely presenting a single embodiment.
Enablement and Written Description Requirementssubscribe to see similar legal issues
Application: A patent must enable a person skilled in the art to make and use the claimed invention without undue experimentation, and must also provide a written description sufficient to demonstrate possession of the claimed invention.
Reasoning: Abiomed contends that the claims should be restricted to cable-driven pumps due to insufficient enablement for other types in the specification.
Means-Plus-Function Claim Interpretationsubscribe to see similar legal issues
Application: When a claim term is considered a means-plus-function term under 35 U.S.C. § 112(f), it is limited to the structures disclosed in the specification and their equivalents.
Reasoning: The term 'guide mechanism adapted to guide said intravascular blood pump and cannula to a predetermined location' will be interpreted as a means-plus-function term, with corresponding structures identified by Abiomed.
Preamble Limitations in Patent Claimssubscribe to see similar legal issues
Application: A preamble in a patent claim is generally not limiting unless it provides essential structure or context necessary to understand the claim.
Reasoning: In this instance, the preamble serves primarily to state the intended use of the invention, while the claims themselves are complete without it.
Prosecution History and Disclaimersubscribe to see similar legal issues
Application: Statements made by a patentee during the prosecution of a patent application can act as disclaimers that limit the scope of the patent claims.
Reasoning: Maquet's statements during prosecution limit the patent's scope, indicating that a person skilled in the art would not combine prior-art references as suggested by the examiner, as this would create an inoperable guidewire lumen impacting the pump's functionality.