Circuit Court Finds Luma’s Endoscopy Patent Invalid And Not Infringed

Holding:

In this appeal, the Federal Circuit affirmed a district court’s entry of summary judgment of non-infringement and invalidity of Luma Corporation’s (“Luma”) medical imaging patent. On the first set of claims, the Federal Circuit held that the district court properly construed a disputed claim limitation in light of its use in the specification and the prosecution history of the patent. Specifically, the district court correctly interpreted the limitation “graphical objects” to exclude text alone. Further, Luma failed to present sufficient evidence to demonstrate a genuine issue of fact as to infringement even under the district court’s construction. On the second set of disputed claims (“Steel Frame Buffer claims”), the Federal Circuit held that Luma’s proposed interpretation lacked support in both the claims and the specification. Luma did not challenge the undisputed facts relied upon by the district court, but only the court’s construction of the limitation “still frame buffer.” Hence, the grant of a summary judgment of invalidity of the second set of claims for anticipation was warranted.

Detailed Summary:

Plaintiff-appellant Luma filed this appeal from the order of the U.S. District Court for the Southern District of West Virginia. The district court entered a summary judgment of non-infringement of certain claims of its ‘801 patent, and of invalidity of the other claims of the same patent.

In September 2002, Luma sued appellees Stryker Corporation and Karl Storz Endoscopy-America, Inc. (“KSEA”) for infringement of the ’801 patent. The ’801patent was entitled “Managing Information in an Endoscopy System,” and described and claims a system for acquiring images during a medical procedure. Two sets of claims from the ’801 patent were at issue.…

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