The Federal Circuit reversed a $106 million jury verdict in the case of Colibri Heart Valve LLC v. Medtronic CoreValve, LLC, affirming that prosecution history estoppel prevents Colibri from pursuing doctrine of equivalents infringement claims based on the strategic cancellation of a broad claim during prosecution. The ruling clarified that the estoppel doctrine now extends beyond traditional claim amendments to include instances of claim cancellations that convey narrowing effects to those skilled in the art. This decision represents a significant expansion of the scope of prosecution history estoppel.
In a significant ruling, the Federal Circuit held that prosecution history estoppel prevents Colibri Heart Valve from claiming doctrine of equivalents infringement based on the cancellation of a broader claim during prosecution, despite the fact that the original claim was never amended. This decision illustrates the court's stance on expanding the reach of estoppel beyond typical claim amendments to include strategic cancellations.
The Federal Circuit's reversal of a $106 million jury verdict underscores the importance of prosecution history estoppel, which now applies to cases where a broad claim is canceled during prosecution, signaling narrowing to skilled individuals in the art and thus limiting potential infringement claims.
#prosecution-history-estoppel #doctrine-of-equivalents #patent-law #federal-circuit #intellectual-property
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