Vascular Sols. LLC v. Medtronic, Inc

Authored by: Jeremy J. Gustrowsky

A recent decision from the Federal Circuit offers important guidance for patent owners and litigants about how patent claims can be drafted and interpreted—especially when it comes to claims that divide up a device in different ways. The case involved a set of patents owned by Vascular Solutions LLC and related companies, covering specialized coaxial guide catheters used in cardiology procedures. Medtronic, Inc. was accused of infringing these patents, which all descended from a common application and shared a similar technical focus.

The dispute centered on the meaning of the term “substantially rigid portion/segment” as used in the patents, including U.S. Patent No. 8,048,032 and several related patents. The district court originally found that the claims were “mutually exclusive” and therefore indefinite—meaning that the same accused product could not possibly infringe two claims that defined the boundaries of the “substantially rigid portion” differently. This led the court to invalidate all the asserted claims, a major setback for the patent owner.

On appeal, the Federal Circuit disagreed with the lower court’s approach. The appellate judges explained that patent claims can, and often do, divide up a device in different ways, and that each independent claim is allowed to set its own boundaries for different portions of a device. The court clarified that the “substantially rigid portion/segment” limitation is a functional one, meaning it is defined by what it does (being rigid enough to allow the device to be advanced), not by a fixed physical boundary that must be the same in every claim. As a result, the court held that the claims were not indefinite simply because they defined the boundaries of the rigid portion differently in different claims.

This decision is a helpful reminder that patent claims are tools for defining an invention in multiple ways, and that courts should not impose uniformity that is not required in the claim language. Instead, each claim should be read on its own terms, as long as it gives clear notice to the public about what is being claimed. The case was sent back to the district court for further proceedings, giving the patent owner another chance to assert its rights.