Federal Circuit rules in Medtronic and St. Jude patent rows

The US Court of Appeals for the Federal Circuit issued two separate judgments concerning the alleged infringement of a patent covering an access control mechanism for a wireless network by medical device makers Medtronic and St. Jude Medical.

At issue in both cases is US patent number 5,371,734 owned by licensing company Atlas IP. The patent is called “Medium Access Control Protocol for Wireless Network” and covers the wireless communication between a hub station and a remote control.

In two separate rulings handed down yesterday, October 29, the federal circuit remanded both cases back to the US District for the Southern District of Florida.

Atlas IP sued St. Jude at the Florida district court in 2013, alleging that devices used to measure a patient’s health condition was infringing the ‘734 patent.

But the infringement claims were rejected before the trial after the court granted St. Jude’s motion for a ruling of non-infringement last year.

However, after Atlas IP appealed against the decision, the federal circuit vacated the ruling and remanded it back to the district court arguing that it erred in its construction of the term “transmitting”, used in various claims for the patent.

The district court ruled that the term covered the hub’s advanced notice of a communication cycle to the remote.

But the federal circuit said the lower court “went beyond that construction” in determining that there had been no infringement.

“Here, we hold in agreement with Atlas, that the claim language at issue does not require that the cycle’s starting time and duration be communicated to the remotes even earlier, i.e., before the communication cycle begins,” the federal circuit said.

Despite the federal circuit’s revival of the St. Jude dispute, it is possible that the ‘734 patent could still be invalidated as a result of the licensing company’s concurrent dispute with Medtronic.

In October 2014, the district court rejected claims that Medtronic’s defibrillators and insulin pumps were infringing the patent, but affirmed that the patent was valid.

Medtronic had specifically targeted claim 21 in the patent as being obvious. Claim 21 outlines the three intervals of the communication cycles between the hub station and the remote.

But Judge Richard Taranto pointed to the “ imprecision” of the language of the claim.

“The district court relied entirely on what it viewed as ‘plain meaning’ of the claim language. The court thought the meaning so plain that it did not even discuss any of the contextual considerations that are often central to claim construction. That was erroneous.

“The claim language does not have the decisive plain meaning the district court found, and contextual considerations point compellingly the other way,” he added.

For this reason, the federal circuit rejected the district court’s claim construction and reversed its judgment that the patent is valid. The federal circuit has remanded the case back to the district court.

A spokesman for Medtronic said it was pleased with the ruling.