In Maquet Cardiovascular LLC v. Abiomed Inc., the Federal Circuit addressed limits on the use of prosecution history in claim construction across patent families. The court vacated a district court's non-infringement judgment, emphasizing that prosecution disclaimer cannot be indiscriminately applied across related patents. The ruling highlights that for claim limitations to carry from one patent to another, there must be significant parity between those limitations. This decision serves as a useful guideline for patent prosecutors on avoiding expansive applications of prosecution disclaimers across family patent claims.
The Federal Circuit reversed the district court's claim constructions that relied on prosecution history from unrelated patents, highlighting the importance of parity in patent claims.
Prosecution disclaimer should not be assumed to apply broadly across family patents unless the claims demonstrate substantial similarity.
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