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ARTICLE · 02 MAY 2025

Federal Circuit Vacates Non-Infringement Judgment Over Improper Claim Construction

Finnegan, Henderson, Farabow, Garrett & Dunner LLP
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In Maquet Cardiovascular LLC v. Abiomed Inc., No. 2023-2045 (Fed. Cir. Mar. 21, 2025), the Federal Circuit vacated a judgment of non-infringement regarding Maquet's U.S. Patent...

United StatesIntellectual Property
Christopher Anderson
Christopher Anderson
Erik Puknys
Erik Puknys
Prince Ene
Prince Ene
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In Maquet Cardiovascular LLC v. Abiomed Inc., No. 2023-2045 (Fed. Cir. Mar. 21, 2025), the Federal Circuit vacated a judgment of non-infringement regarding Maquet's U.S. Patent No. 10,238,783, ruling that the district court improperly narrowed the claim scope by misapplying prosecution disclaimer.

Marquet asserted that Abiomed infringed certain claims of the '783 patent directed to a system for deploying a blood pump to a desired location in a patient's circulatory system. At issue on appeal were the district court's claim construction rulings related to three terms in the '783 patent. The district court accepted Abiomed's arguments that prosecution history from prior applications required reading negative limitations into the claims—namely, that the claimed “guide mechanism comprising a lumen” does not encompass a lumen that is distal to a cannula or that passes through the pump's rotor blades.

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