Medline Industries, LP v. C.R. Bard, Inc.

CourtDistrict Court, N.D. Georgia
DecidedFebruary 20, 2024
Docket1:20-cv-03981
StatusUnknown

This text of Medline Industries, LP v. C.R. Bard, Inc. (Medline Industries, LP v. C.R. Bard, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Medline Industries, LP v. C.R. Bard, Inc., (N.D. Ga. 2024).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

MEDLINE INDUSTRIES, L.P., Plaintiff, v. CIVIL ACTION NO. 1:20-CV-03981-JPB C.R. BARD, INC.,

Defendant.

ORDER

This matter is before the Court on the Special Master’s Report and Recommendation [Doc. 137] regarding the claim construction of certain terms in United States Patent No. 8,448,786 (“the ’786 Patent”). This Court finds as follows: FACTS AND PROCEDURAL HISTORY This is a dispute concerning the ’786 Patent, which is entitled “Catheter Tray, Packaging System, Instruction Insert, and Associated Methods.” In this case, Medline Industries, L.P. (“Plaintiff”) alleges that C.R. Bard, Inc. (“Defendant”) infringed Claim 1 of the ’786 Patent. Claim 1 reads as follows: A method of using a catheter package assembly, comprising:

opening a thermally sealed bag disposed about a tray having a catheter assembly disposed therein; accessing an instruction manual;

unfolding one or more layers of wrap to reveal an additional layer of wrap and the catheter assembly; and

placing one of the one or more layers of wrap or the additional layer of wrap beneath a patient, thereby transforming an area beneath the patient from a non-sterile field to a sterile field.

[Doc. 1, p. 13]. Here, the parties dispute certain terms contained in Claim 1 of the Patent. More specifically, the parties disagree as to the construction of “catheter assembly” and the construction of “reveal” or “reveal an additional layer of wrap and the catheter assembly.” On November 30, 2022, the Court appointed William H. Needle as Special Master to preside over claim construction in this case under Markman v. Westview Instruments, Inc., 52 F.3d 967 (Fed. Cir. 1995).1 [Doc. 115]. The Special Master issued his Report and Recommendation, which contained three distinct recommendations, on May 2, 2023. [Doc. 137]. First, the Special Master recommended that the qualifications of a person of ordinary skill in the art as to the ’786 Patent is “one who would have a bachelor’s degree in mechanical engineering

1 The Court’s appointment of Mr. Needle was not limited to claim construction alone. Claim construction, however, is the only issue presently before the Court. or equivalent technical degree and at least two years of experience in the medical device packaging field.” Id. at 14. Second, as to the first disputed term—"catheter assembly”—the Special Master recommended the following construction: “a coiled medical device that includes a catheter connected via tubing to a drainage

receptacle.” Id. at 24. Third, as to the second disputed term —“reveal” and “reveal an additional layer of wrap and the catheter assembly”— the Special Master recommended construing “reveal” to mean “to make visible or able to be

seen” and construing “reveal an additional layer of wrap and the catheter assembly” to mean “to make an additional layer of wrap and the catheter assembly visible or able to be seen.” Id. at 28. On May 16, 2023, both parties filed objections to the Special Master’s

Report and Recommendation. [Doc. 138]; [Doc. 140]. LEGAL STANDARD 1. Standard of Review of the Report and Recommendation

In acting upon a Special Master’s report, courts have broad discretion to “adopt or affirm, modify, wholly or partly reject or reverse, or resubmit to the master with instructions.” Fed. R. Civ. P. 53(f)(1). Importantly, where, as here, objections are made to either the findings of facts or the conclusions of law, the

objections must be decided de novo. See Fed. R. Civ. P. 53(f)(3)-(4). 2. Standard of Review for Claim Construction The first step of an infringement analysis is “a construction of each asserted claim to determine the subject matter encompassed thereby.” Trovan, Ltd. v. Sokymat SA, Irori, 299 F.3d 1292, 1302 (Fed. Cir. 2002). Claim

construction “is a question of law, to be determined by the court.” Markman, 517 U.S. at 384. A patent’s claimed terms “are generally given their ordinary and customary meaning.” Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed. Cir.

2005). Notably, this refers to the “meaning that the term would have to a person of ordinary skill in the art in question at the time of the invention.” Id. at 1313. In construing claims, a court’s “analysis must begin and remain centered on the claim language itself, for that is the language the patentee has chosen to

particularly point out and distinctly claim the subject matter which the patentee regards as his invention.” Innova/Pure Water, Inc. v. Safari Water Filtration Sys., Inc., 381 F.3d 1111, 1116 (Fed. Cir. 2004). Moreover, a court must also interpret

claims “with an eye toward giving effect to all terms in the claim,” Bicon, Inc. v. Straumann Co., 411 F.3d 945, 950 (Fed. Cir. 2006), and should avoid an interpretation that renders terms superfluous, Merck & Co. v. Teva Pharm. USA, Inc., 395 F.3d 1363, 1372 (Fed. Cir. 2005). “In some cases, the ordinary meaning of claim language as understood by a person of skill in the art may be readily apparent even to lay judges, and claim construction in such cases involves little more than the application of the widely accepted meaning of commonly understood words.” Phillips, 415 F.3d at 1314.

However, because the meaning of a claimed term is often not immediately apparent, courts look to “sources available to the public that show what a person of skill in the art would have understood disputed claim language to mean.” Id.

These include “the words of the claims themselves, the remainder of the specification, the prosecution history, and extrinsic evidence concerning relevant scientific principles, the meaning of technical terms, and the state of the art.” Id. Although extrinsic evidence may “shed useful light on the relevant art,” it is

considered “less significant than the intrinsic record in determining the legally operative meaning of claim language.” Id. at 1317. Indeed, a court should not rely on extrinsic evidence unless the intrinsic evidence is insufficient to enable the

court to determine the meaning of the asserted claims. Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1584 (Fed. Cir. 1996). DISCUSSION As stated above, both parties filed objections to the Report and Recommendation. The objections will be discussed as they relate to the Special Master’s recommendations.

1. Level of Skill in the Art “One must bear in mind . . . that patents are ‘not addressed to lawyers, or even to the public generally,’ but rather to those skilled in the relevant art.”

Nautilus Inc. v. Biosig Instruments, Inc., 572 U.S. 898, 909 (2014). Thus, a threshold inquiry in the claim construction process is “how a person of ordinary skill in the art would have understood claim terms at the time of the invention.” Pfizer, Inc. v. Teva Pharm., USA, Inc., 429 F.3d 1364, 1372-73 (Fed. Cir. 2005).

This inquiry “provides an objective baseline from which to begin claim interpretation.” Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Medline Industries, LP v. C.R. Bard, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/medline-industries-lp-v-cr-bard-inc-gand-2024.