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Fresenius USA, Inc. v. Baxter International, Inc.
United States Court of Appeals for the Federal Circuit
582 F.3d 1288 (2009)
Baxter International, Inc. (Baxter) (defendant) owned three patents claiming dialysis machines incorporating touchscreen user interfaces. One of the patents asserted claims with nontouchscreen limitations. Fresenius USA, Inc. (Fresenius) (plaintiff) sued to invalidate Baxter’s patents after it started selling an alleged infringing device. Fresenius presented a prior-art publication disclosing an anesthesia-delivery system having a touchscreen interface that mentioned the benefit touchscreen technology would add to dialysis equipment by improving the user interface. The publication’s author testified that the publication suggested combining touchscreens with dialysis equipment, and an expert witness testified that one of ordinary skill in the art would have been able to make the combination. After a trial on validity, a jury found claims of one patent were anticipated and all other claims were obvious. Baxter only challenged the obviousness verdict. The district court granted judgment as a matter of law (JMOL), overturning the verdict after finding Fresenius failed to show that, at the time of invention, nontouchscreen limitations existed in the art or a motivation to combine existing touchscreen and dialysis technologies. This appeal followed.
Rule of Law
Holding and Reasoning (Gajarsa, J.)
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