Howmedica Osteonics Corp v. Wright Medical Technology, Inc.

Howmedica Osteonics, Corp. v. Wright Medical Technology, Inc., 540 F.3d 1337 (Fed. Cir. 2008).

Facts: Both Howmedica and Wright develop, manufacture, and sell orthopedic implants. Howmedica owns the '100 patent, which covers an artificial knee prosthesis or implant used to replace, in part or whole, a person's knee joint. Claims 15 and 18 are at issue. Four separate suits had been ongoing between the parties for some time. They came to an agreement whereby Wright would be released from any liability from the suits.

Procedural History: Howmedica filed suit against Wright for infringement of the '100 patent, which had not previously been litigated. Wright claimed that Howmedica was barred based on their agreement. Both parties filed motions for summary judgment on Wright's release defense. The district court denied Wright's motion and held in favor of Howmedica. The district court then issued a claim construction order concerning three disputed terms in claim 15. First, the district court construed the phrase "femoral component including at least one condylar element" to require, in a bicondylar femoral component, both condyles to meet the geometric limitations of the claim. Second, the district court construed "primary range of flexion" to be limited to a particular range
of -15o of hyperextension to +75o of flexion, in accordance with the specification. Finally, the district court construed the phrase "lying generally along a line extending laterally between the medial and lateral collateral ligament attachment points on the femur of the natural knee" as definite. Howmedica could not show that Wright's device infringed based on these constructions. The district court held in favor of Wright, finding noninfringement. Howmedica appealed.

Issue: Whether the district court's claim construction of the terms was correct.

Holding: No, the claims should be interpreted by their plain language. Vacated and remanded.

Reasoning: Based on the plain language of the claim, the construction of claim 15 does not need to conform to the specified geometry. The court also held that the claim language does not need to encompass every purpose of the invention. Further, the fact that the specification only includes one embodiment does not limit broad claim language. The court rejected a letter between the attorney and patent applicant as part of the prosecution history to limit the language. It is merely extrinsic evidence and, in this case, is of no value. The district court's claim construction was erroneous.

Analysis: It was interesting to see how much evidence and how many arguments were actually introduced in determining the meaning of words, and, ultimately, that everything was rejected in favor of the plain meaning of the terms.
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