SciMed Life Systems, Inc. v. Advanced Cardiovascular Systems, Inc.

SciMed Life Systems, Inc. (SciMed) (plaintiff) owned three patents covering components of balloon dilation catheters used to unblock arteries. The patents disclosed catheters with three sections and two lumens, a guide-wire lumen and an inflation lumen, arranged in a coaxial configuration where the guide-wire lumen runs inside an annularly shaped inflation lumen. The patent specifications provided that the coaxial lumen configuration is superior to prior art dual lumen configurations because of decreased shaft size and increased flexibility. Additionally, the specifications indicated repeatedly that the claimed invention employs coaxial, and not dual, lumens, and that the described structure is the basic structure for all embodiments of the invention contemplated by the patent. SciMed brought suit against Advanced Cardiovascular Systems (ACS) (defendant) claiming that ACS’s catheters, which employed a dual lumen configuration, infringed the patents. ACS moved for summary judgment. Based on the specification language, the court granted ACS’s motion, concluding that the patent claims were limited to coaxial lumens, and that ACS’s dual lumen catheters were therefore noninfringing. In addition to a lack of literal infringement, the court further concluded that, because ACS’s dual lumen catheters were sufficiently dissimilar to those disclosed in SciMed’s patents, no reasonable jury could find the patents infringed under the doctrine of equivalents. SciMed appealed.