Hill-Rom Services, Inc. v. Stryker Corporation
755 F.3d 1367
| Fed. Cir. | 2014Background
- Patents ('038, '592, '659) claim systems/methods for remotely monitoring hospital bed status via sensors, an on‑bed interface board (processor), a datalink, and a remote processing station.
- Hill‑Rom sued Stryker for infringement; the district court granted summary judgment of non‑infringement based on its claim constructions for four terms: “datalink,” “interface board including a processor,” “message validation information,” and “bed condition message.”
- Parties stipulated non‑infringement contingent on those constructions; Hill‑Rom appealed. The Federal Circuit reviews claim construction de novo.
- Disputed terms centered on whether (1) “datalink” is limited to a wired cable vs. wired or wireless, (2) the interface board must send/receive via a wall interface unit and always be two‑way, (3) “message validation information” must guarantee bit‑perfect receipt, and (4) “bed condition message” is limited (by judicial estoppel) to non‑user‑requested messages containing all bed conditions.
- The Federal Circuit majority reversed, holding the district court erred by importing limitations from the specification or later prosecution statements into the claims and adopted broader constructions for the disputed terms.
Issues
| Issue | Hill‑Rom (Plaintiff) Argument | Stryker (Defendant) Argument | Held |
|---|---|---|---|
| Meaning of “datalink” | Plain meaning: any link carrying data; includes wired and wireless | Patents limited datalink to a wired cable (based on spec embodiments) | “Datalink” = any link over which data is transferred; can be wired or wireless; specification did not lexicographically or by disavowal limit term to cable |
| “interface board including a processor” — required functions/structure | Plain meaning: on‑bed interface that processes bed inputs into bed condition messages and interfaces to off‑bed components; need not receive remote messages or route via wall unit unless claim says so | Specification requires interface board to send/receive via wall interface unit and be capable of two‑way communication | Interface board must receive bed inputs, create bed condition messages, and send to remote processing station; some claims (e.g., claim 13) expressly add receiving-from-remote requirement; no implied wall‑unit limitation where claim silent |
| “message validation information” | Should mean information that validates a message; can be implemented by disclosed CHECKSUM (coarse verification) | District court limited to a data field that verifies exact bit‑for‑bit receipt | “Message validation information” = one or more data fields in a message used to verify that the message was received exactly the same as sent; not limited to a single field; verification need not be flawless |
| “bed condition message” / judicial estoppel | Plain meaning: a message indicating status of a monitored bed; need not be non‑user‑requested nor include all monitored conditions | District court invoked judicial estoppel from Hill‑Rom’s statements in prosecution of later unrelated patent to limit term to non‑user‑requested messages containing all conditions | Judicial estoppel inapplicable: statements during prosecution of a later, unrelated patent cannot limit earlier patent claims; “bed condition message” = message that indicates status of a monitored bed (plain meaning) |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claims construed in light of specification and prosecution history; ordinary meaning to a person of skill in the art at filing date)
- Liebel‑Flarsheim Co. v. Medrad, Inc., 358 F.3d 898 (Fed. Cir. 2004) (do not import limitations from specification; dependent claim adds presumption that limitation is not in independent claim)
- Thorner v. Sony Computer Entm’t Am. LLC, 669 F.3d 1362 (Fed. Cir. 2012) (lexicography and disavowal are the only bases for departing from ordinary meaning)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir. 1996) (construction excluding the preferred embodiment is rarely correct)
- Pfizer, Inc. v. Ranbaxy Labs., Ltd., 457 F.3d 1284 (Fed. Cir. 2006) (statements during prosecution of a later, unrelated patent cannot be used to interpret claims of an earlier patent)
- Greenberg v. Ethicon Endo‑Surgery, Inc., 91 F.3d 1580 (Fed. Cir. 1996) (functional term definitions do not necessarily invoke 35 U.S.C. § 112(f))