Federal Circuit Finds Cordis' Cardiac Catheters Infringed Dr. Voda's Patents, But Affirms Denial of Injunctive Relief

Holding:

The U.S. Court of Appeals for the Federal Circuit affirmed a jury's finding that Cordis Corp.'s curved catheter infringed Dr. Jan K. Voda's patented catheters that consisted of straight portions. The Federal Circuit explained that Voda introduced substantial evidence establishing that the redesigned curve portion of the XB catheter meets the "straight" and "substantially straight limitations" under the doctrine of equivalents. On the issue of willfulness, the Federal Circuit found that, based on case records, a jury instruction in accord with the In re Seagate objective recklessness standard may have changed the result of the jury verdict on willfulness. Accordingly, it vacated the finding of willfulness and remanded the case for a determination of whether Cordis’ infringement was willful under the objective recklessness standard of Seagate. With regard to the district court's denial of permanent injunction, the Federal Circuit rejected Voda's argument based on the irreparable harm to its exclusive licensee. The Federal Circuit reasoned that irreparable harm must fall on the party seeking injunction. Here, Voda failed to show that Cordis’s infringement caused him irreparable injury and that monetary damages were inadequate to compensate him. Accordingly, the Federal Circuit affirmed the district court’s denial of Voda’s request for a permanent injunction.

Detailed Summary:

This is a patent infringement case involving catheters used in interventional cardiology. The issues on appeal and cross-appeal include claim construction, patent validity, infringement, willfulness, and the district court’s denial of a permanent injunction. Opinion, p. 1.

Dr. Jan K. Voda, M.D., (“Voda”) sued Cordis Corporation (“Cordis”) for infringement of his ’625 patent, ’213 patent, and ’195 patent in the United States District Court for the Western District of Oklahoma. The parties tried the case to a jury, and it returned a verdict finding that Cordis willfully infringed all asserted claims of the patents-in-suit and that claims 1 through 3 of…

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