Retractable Technologies, Inc. v. Becton, Dickinson and Co.

Retractable Technologies, Inc. (Retractable) (plaintiff) and Becton, Dickinson and Co. (Becton) (defendant) made and sold medical syringes with retractable needles. Retractable sued Becton for patent infringement in federal court, alleging syringes made by Becton violated several patents owned by Retractable. The body of the Becton syringe was made of multiple pieces. Retractable’s patent claims recited a syringe including a body that held a needle-retraction mechanism. The claims did not describe a body made from multiple pieces and left open the question of whether syringes with multiple-piece bodies fell within the bounds of the patents. The patent specification stated that the outer structure was a single part and distinguished the invention from prior art by noting that the prior art failed to acknowledge syringes made with only one body piece. The specification also stated that each embodiment’s body had one piece. Only illustrations of syringes with one body piece were included in the specification. The specification included no language or figures representing syringes with multiple body pieces. The district court broadly construed the term body to include multiple-piece structures. A jury found that Becton had infringed claims of the Retractable patents and had failed to prove that the Retractable patents were invalid. After trial, Becton moved for judgment as a matter of law on the issues of noninfringement and invalidity. The district court denied Becton’s motion and entered final judgment in the case. Becton appealed.