Advance Medical Designs, Inc. v. Corbin Clinical Resources, LLC, 1:22-cv-00789

Plaintiff Advanced Medical Designs, Inc. (AMD) sought declaratory judgment of non-infringement and invalidity for patents held by Defendant Corbin Clinical Resources, LLC (Corbin), who counterclaimed for infringement.
The patents at issue relate to methods and devices for transperineal ultrasound-guided prostate biopsies, invented to reduce infection risks by avoiding the rectum.
Initial litigation focused on three patents; two additional patents were added as the USPTO granted them, leading to multiple rounds of claim construction briefing and hearings, complicated by ongoing PTO proceedings.
The court's opinion addresses the construction of eleven disputed claim terms across five asserted patents after unsuccessful settlement negotiations and procedural motions (including motion to stay).
Both parties used positions taken during patent prosecution and PTO proceedings (including IPRs and PGRs) to argue for or against limiting the language of the claims; much of the dispute focused on whether prosecution history statements amounted to a clear disclaimer of claim scope.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether "pair of stabilization bars" should have a narrow construction per prosecution history	Corbin disclaimed broader meaning during prosecution to distinguish prior art.	No clear and unmistakable disclaimer; plain meaning controls.	Plain and ordinary meaning applies.
Whether "an upper mount and a lower mount..." is limited per amendments	Amendment intended to distinguish prior art, precludes certain structures (e.g., Onik device, BK Medical).	Any amendment was not necessary to avoid prior art and does not evidence disavowal.	No disavowal; plain and ordinary meaning applies.
Whether limitations about the engagement of the needle/platform must be read into "platform configured to slide..."	Claims require the platform/needle to engage prior to sliding; prosecution and specification support this.	Claim language and doctrine of claim differentiation weigh against importing further limitations.	No imported timing/engagement limitation; plain meaning applies.
Whether terms relating to "coupling/securing" access needles require a temporal limitation during insertion	Prosecution and PGR history require needle to be coupled throughout insertion to distinguish Onik.	No such limitation in claim/specification; PGR/PTAB confirmed ordinary meaning is sufficient.	No temporal limitation; plain and ordinary meaning governs.

Markman v. Westview Instruments, Inc., 517 U.S. 370 (claim construction is a question of law for the court)
O2 Micro Int’l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351 (clarifies when claim construction is needed for terms with ambiguous meanings)
Phillips v. AWH Corp., 415 F.3d 1303 (explains standard for claim construction and use of intrinsic/extrinsic evidence)
Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (places high value on specification in claim construction)
Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co., 535 U.S. 722 (discusses presumption of disclaimer via claim amendments)
Nazomi Commc’ns, Inc. v. Arm Holdings, PLC, 403 F.3d 1364 (explains doctrine of claim differentiation)
Renishaw PLC v. Marposs Societa’ per Azioni, 158 F.3d 1243 (describes breadth of generic claim language)
Southwall Techs., Inc. v. Cardinal IG Co., 54 F.3d 1570 (prosecution history limits interpretations that were disclaimed)