St. Jude Medical, Inc. v. Access Closure, Inc.

St. Jude Medical, Inc. (St. Jude) (plaintiff) sued Access Closure, Inc. (defendant) in federal district court, alleging infringement of several patents, including St. Jude’s “Janzen patent.” The Janzen patent descended from a grandparent patent that the federal Patent and Trade Office (PTO) restricted in order to undo the impermissible mixing of two genus groups, the first of which pertained to medical vascular-puncture procedures, and the second of which pertained to vascular-puncture methods. Each genus contained three species. The resulting grandparent patent pertained only to devices in genus I, species B. St. Jude later applied for a divisional patent that became the parent of the patents relevant to the patent-infringement case. While the divisional-patent application was still pending, St. Jude obtained a child patent continuing the grandparent and parent patents and adding coverage for all three species of genus II. This became the “sibling” of St. Jude’s Janzen patent, which covered the “C” species of both genera. The district-court jury entered judgment for St. Jude on most counts. However, the jury found that the Janzen patent was an invalid double patent of the sibling patent. The court overrode that finding and ruled that a safe harbor provided by 35 U.S.C. § 121 saved the Janzen patent from invalidation. Access Closure appealed the court’s ruling to the Federal Circuit.