Summary: CAFC reverses judgment of no infringement due to erroneous claim construction.
Case: Hill-Rom Servs., Inc. v. Stryker Corp., No. 2013-1450 (Fed. Cir. June 27, 2014) (precedential). On appeal from S.D. Ind. Before Moore, Schall, and Reyna.
Procedural Posture: Plaintiff-patentee Hill-Rom appealed from the district court’s grant of summary judgment of no infringement in favor of Stryker. CAFC reversed and remanded.
- Claim Construction: In the context of the asserted patents, which were directed to hospital bed monitoring systems, the district court erred construing the term “datalink” to mean “a cable connected to the bed that carries data,” where neither the specification nor prosecution history gave reason to limit the term to wired connection. CAFC held that “datalink” should be given its plain and ordinary meaning at the time of the patent filing, which was a link that carries data in a wired or wireless fashion.
- Claim Construction: The district court erred construing the term “interface board including a processor” to mean “a board that processes an input signal to create bed condition messages and sends those messages to a remote location via the wall interface unit.” CAFC found that under principles of claim differentiation, this construction improperly imported limitations into the claim. CAFC held that this term means the interface between the bed components and the off-bed components that process the bed conditions input signals.
- Claim Construction: The district court erred construing the term “message validation information” as “a data field within a message that is used to verify that the message was received exactly the same time it was sent” because the references are not sufficient to limit the structure of the message validation information to a single field. CAFC construed “message validation information” as one or more data fields within a message that is used to verify that the message was received exactly the same time as it was sent.
- Claim Construction: The district court erred construing the term “bed condition message” as “a message not generated in response to any user request that contains the status of all conditions the bed is capable of monitoring.” Particularly because the parties did not dispute the meaning of this term and the specification did not provide any reason to depart from the plain and ordinary meaning, CAFC held that the term “bed condition message” is a message that indicates the status of a monitored bed condition.
Reyna disagreed with the CAFC construction of “datalink” because (1) the intrinsic record is devoid of any description of a wireless “datalink” structure; (2) extrinsic evidence belies the majority’s conclusion that “datalink” encompasses wireless communication; and (3) the majority relies on expert testimony that is conclusory and unreliable.