The Federal Circuit overturned a jury's willful-infringement verdict concerning patents held by LabCorp. It deemed the jury's claim construction decision as erroneous, citing O2 Micro error, and stated the patentee's doctrine-of-equivalents showing did not meet the function-way-result test. The patents involved describe methods to prepare DNA samples for sequencing by focusing on specific regions of interest to enhance efficiency. Originally, a jury found Qiagen's products infringed the patents, awarding $5 million in damages before the federal appeal reversed this decision.
The Federal Circuit set aside a Delaware jury's willful-infringement verdict and directed entry of JMOL of non-infringement on two Mass General patents now owned by LabCorp.
The panel held that the district court improperly let the jury decide a disputed claim construction and that the patentee's doctrine-of-equivalents showing failed the function-way-result test.
The case centered on U.S. Patents 10,017,810 and 10,450,597, which describe methods for producing copies of specific DNA regions to make sequencing more efficient.
After a five-day jury trial, the jury found that Qiagen's accused products willfully infringed both patents, awarding about $5 million in damages.
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