In St. Jude Medical, LLC v. Snyders Heart Valve LLC, Nos. 2019-2108, 2019-2109, 2019-2140 (Fed. Cir. Oct. 15, 2020), the Federal Circuit held valid all challenged claims of Snyders' artificial heart valve patent.
On appeal, St. Jude first disputed the Board's application of its construction of "band." The Board substantially adopted the construction advanced by St. Jude, requiring that it be a "closed ring or strip." The Board held that prior art disclosing a "sleeve" did not disclose a "closed ring or strip." St. Jude argued that the Board changed its construction upon application because "band" should not inherently include a limitation on length or width. The Federal Circuit found this argument "meritless," relying on St. Jude's own use of terms "strip" and "ring" within its construction and being distinguishable from the "sleeve" of the prior art.
Second, Snyders disputed whether other claims were anticipated by the prior art. The Federal Circuit overturned the Board's anticipation holding, determining that the prior art that did not disclose native valve removal did not anticipate the claims because the patent specifically claimed the ability to insert an artificial valve without native valve removal.
Finally, The Federal Circuit also rejected St. Jude's obviousness arguments because St. Jude failed to prove that a skilled artisan would combine specific elements of each reference to arrive at the challenged claims.
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