St. Jude Medical, LLC v. Snyders Heart Valve LLC

The Court of Appeals for the Federal Circuit (Federal Circuti) in St. Jude Medical, LLC v. Snyders Heart Valve LLC held that the broadest reasonable interpretation of a claim must be considered in light of the specification.

Background

St. Jude Medical, LLC petitioned twice for inter partes review of a patent owned by Snyders Heart Valve LLC. The claim at issue was directed to an artificial heart valve and a system for inserting the valve. The heart valve can be installed via catheter without invasive surgery and without a need for removal of the patient”™s diseased heart valve.

In response to the petition at issue, the PTAB found that four of these claims were anticipated by the prior art.

In finding the prior art”™s anticipation of these four claims, the claim recitations at issue was a “frame sized and shaped for insertion between the upstream region and the downstream region”, and the PTAB applied the “broadest reasonable interpretation” of these claim recitations. Based on the prior art disclosed a valve insert sized to fit the valve after the damaged native valve was removed, the PTAB under the broadest reasonable interpretation interpreted “frame sized and shaped” as also covering a frame that fits in place after removal of a damaged heart valve. Therefore, the PTAB found that the prior art anticipated the claims.

CAFC’s Analysis

The Federal Circuit reversed. The Federal Circuit held that the prior art required removal of a damaged native heart valve before placing the artificial valve. In contrast, the Snyders Heart Valve LLC patent specification disclosed that the disclosed artificial heart valve can be inserted without removing the native valve and expressly indicated that this feature was an improvement over the prior art. The Federal Circuit found that the PTAB failed to take such language in the specification into consideration for the broadest reasonable interpretation. Accordingly, the PTAB improperly construed the “sized and shaped” limitation as covering an artificial valve fitted for the space left after removing the native valve. Instead, the Federal Circuit held that, in light of the specification disclosure discussed, the claim at issue was not anticipated by the prior art.

S&H”™s Analysis

This case reconfirms the patent policy that the broadest reasonable interpretation of the claims should still be interpreted in light of the specification.