Federal Circuit Chooses Absurdity Over Judicial Claim Redrafting
By Chinh Vo – Edited by Jad Mills
Haemonetics Corp. v. Baxter Healthcare Corp., No. 2009-1557 (Fed. Cir. June 2, 2010)
On June 2, 2010, the Court of Appeals for the Federal Circuit reversed the claim construction of the District Court for the District of Massachusetts and vacated a jury verdict in favor of the plaintiff in a patent infringement suit.
Haemonetics Corp. (“Haemonetics”) had filed a patent infringement lawsuit against Fenwal Inc. (“Fenwal”) alleging infringement of its patent for a compact blood centrifuge device. The district court, after construing the last two references to the term “centrifugal unit” in claim 16 as referring to only the centrifugal vessel and not also its adjoining tubing, had awarded over $11.3 million in lost profits damages and over $4.3 million in reasonable royalty damages. The appeals court disagreed with the district court’s claim construction, noting that language from the claim preamble clearly defined a centrifugal unit as including both “a centrifugal component and a plurality of tubes.” The court then vacated and remanded the jury verdict, the district court’s grant of judgment as a matter of law (“JMOL”) that claim 16 was not indefinite, the district court’s denial of JMOL that claim 16 was neither anticipated by prior invention nor obvious, and the district court’s award of prospective remedies, finding that all of these determinations relied on the district court’s erroneous claim construction.