Niazi Licensing Corporation, v. St. Jude Medical S.C., Inc.

30 F.4th 1339 (2022)

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Legal Analysis

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Nature Of The Case

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Facts

There are different methods available for treating heart failure, such as medication or a heart transplant. Resynchronization therapy uses electrical leads (called pacing leads) to help keep the two sides of the heart contracting with regularity and in sync. According to P's '268 patent, at the time of the invention, physicians accomplished resynchronization therapy by inserting a catheter into the coronary sinus and its branch veins (i.e., cannulating) to place pacing leads on the hearts of patients with heart failure. Because the target coronary branch veins arise at acute angles to the coronary sinus and because heart failure can cause changes in the heart's anatomy (including, for instance, the location, shape, and size of the coronary sinus and the branch veins), the specification explains that it can be 'difficult to pass a lead' into the coronary sinus and its branch veins using a catheter. The '268 patent developed a double catheter-i.e., a catheter comprising an outer and inner catheter-for cannulating the coronary sinus 'without significant manipulation.' P made an apparatus claim (claim 1) and a method claim (claim 11). P sued Jude (D) for infringement. The district court determined that the terms 'resilient' and 'pliable' in independent claims 1, 13, 18, and 24 of the '268 patent rendered those claims and their dependents (claims 10, 14-15, 19, 23, and 25-27) indefinite. The court then considered independent claim 11, the only asserted claim that does not recite the terms 'resilient' or 'pliable.' The parties first disputed whether the term 'the catheter' in claim 11 rendered that claim indefinite based on a lack of antecedent basis in the claim. The court determined that the claim was not indefinite, construing 'the catheter' to mean 'the double catheter.' P appealed in part on the district court's determination that claims 1, 10, 13-15, 18-19, and 23-27 are invalid as indefinite.

Issues

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Holding & Decision

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