Haemonetics v. Baxter Healthcare (Fed. Cir. 2010)
This decision is important for its endorsement of the claim construction canon that the internal logic and grammar of an individual claim takes primacy over inter-claim consistency.
Haemonetics’ asserted claim was directed to: 16. A centrifugal unit comprising a centrifugal component and a plurality of tubes . . . with the centrifugal unit having a radius between 25 and 50 mm and a height between 75 and 125% of the radius.
The preamble of Claim 16 clearly indicates that the centrifugal unit includes both a centrifugal component a plurality of tubes. However, other claims and the specification indicate that the centrifugal unit did not include the tubes.
On appeal, the Federal Circuit held that the clarity of Claim 16 controlled the term’s construction for that claim. Regardless of its use elsewhere, in claim 16, the centrifugal unit includes the tubes.
[C]laim 16’s beginning and, in our view, controlling language could hardly be clearer. Claim 16 states: “A centrifugal unit comprising a centrifugal component and a plurality of tubes . . . .” It does not merely state the intended field of use in a preamble, as Haemonetics argues. Rather, it unambiguously defines “centrifugal unit” as “comprising” two structural components: a centrifugal component and a plurality of tubes. The claim then further recites, not the centrifugal component and not a centrifugal unit, but “the centrifugal unit” as “having a radius between 25 and 50 mm and a height between 75 and 125% of the radius.” Reading “the centrifugal unit” in the context of the dimensional limitations to refer exclusively to the vessel, as the district court did, ignores the antecedent basis for “the centrifugal unit,” and fails to give effect to the claim language “comprising a centrifugal component”.
. . .
The patentee’s inconsistent use of identical height and radius limitations for two different embodiments thus indicates that “the centrifugal unit” inthe context of the dimensional limitations must have different meanings in the context of different claims. (internal citations omitted)
The Massachusetts-based district court had reached the opposite conclusion. Based on the erroneous construction, the Federal Circuit vacated the jury verdict and remanded for a new application of the facts.