Atlas IP, LLC v. Medtronic, Inc.
Addressing claim construction issues, the U.S. Court of Appeals for the Federal Circuit affirmed in part, reversed in part and remanded a district court’s summary judgment rulings finding that the district court did not properly consider the disputed terms in the context of the claims and the specification. Atlas IP, LLC v. Medtronic, Inc., Case Nos. 15-1071; -1105 (Fed. Cir., Oct. 29, 2015) (Taranto, J.).
Atlas sued Medtronic alleging infringement of a patent related to a protocol for controlling wireless network communications between a hub and remotes. The district court had already construed the claims of this patent in a related case (Atlas IP, LLC v. St. Jude Medical, Inc.), and adopted those constructions here. The district court granted summary judgment in Medtronic’s favor with respect to non-infringement and in Atlas’ favor with respect to a lack of anticipation or obviousness. Atlas appealed the non-infringement ruling, and Medtronic cross-appealed the validity ruling.
The Federal Circuit began its analysis noting that the question of infringement turned entirely on the proper construction for the term “establishing.” The district court held that the term “establishing” required the endpoint of the communication cycle to be communicated to the remotes before any remote transmits frames to the hub. On appeal, Atlas argued that the term “establishing” should be construed as “initiating,” in accordance with its plain and ordinary meaning. According to Atlas, “initiating” meant that the hub need not define the start and duration of communication cycles and their intervals, let alone transmit that definitional information. The Court disagreed, explaining that, in the context of the patent, the word must mean more than simply “initiating.” Rather, the context made clear that “establishing” means that information must be sent before the remotes begin transmitting. The Court also rejected Atlas’ reliance on a claim differentiation argument, explaining that the Court has “been cautious in assessing the force of claim differentiation in particular settings, recognizing that patentees often use different language to capture the same invention, discounting it where it is invoked based on independent claims rather than the relation of an independent and dependent claim, and not permitting it to override the strong evidence of meaning supplied by the specification.”
Next, the Court turned to the district court’s validity ruling, which likewise turned on a claim construction issue. Here, the Court found that “the district court’s construction is ambiguous on its face.” The district court’s construction was based on the plain and ordinary meaning of the disputed claim term. Looking again to the context provided by the claims and specification, the Court reversed the district court, finding that the district court erred by not “rely[ing] on anything for its construction except the claim words understood in isolation.”
The same day, the Federal Circuit issued another opinion vacating and remanding the district court’s summary judgment of non-infringement in the above-discussed related case, finding that the court’s holding was based on an incorrect claim construction. Atlas IP, LLC v. St. Jude Medical, Inc., Case No. 15-1190 (Fed. Cir., Oct. 29, 2015) (Taranto, J.). Here, the Federal Circuit disagreed with the district court’s construction of the term “in advance,” which appears in the same patent. According to the Court, the district court’s construction was overly narrow when the disputed term is properly considered in the context of the claim language and the specification