District Court Erroneously Gives Claim Term Two Different Constructions in a Single Claim

Haemonetics Corp. v. Baxter Healthcare Corp. (Fed. Cir. Jun. 2, 2010)

In this case, the Federal Circuit held that the district court erroneously gave the claim term "centrifugal unit" two different constructions for different instances of the term in a single claim and remanded the proceedings back to the district court.

The patent at issue related to a compact blood centrifuge device for separating and collecting components in a liquid such as blood.  In the asserted claim, the claim preamble stated "A centrifugal unit comprising a centrifugal component and a plurality of tubes" and the term "the centrifugal unit" also appeared twice in the body of the claim.  The district court construed the term "centrifugal unit", as found in the preamble, as comprising both the vessel and the tubing but also construed the same term, as found in the claim body, as comprising only the vessel.  The district court had reasoned that given certain dimensional limitations in the claim body, giving the term, as found in the claim body, a construction that includes the tubing "would yield an absurdity."

The Federal Circuit disagreed, stating that claim construction occurs "with an eye toward giving effect to all [] terms … even if it renders the claims inoperable or invalid."  In this particular case, the Federal Circuit found that the preamble language of the claim did not merely state the intended use but instead was controlling and defined "centrifugal unit" as comprising "two structural components: a centrifugal component and a plurality of tubes."  While the court acknowledged that an error may have occurred in drafting this claim, "it is what the patentee claimed and what the public is entitled to rely on."  The court went on to state that "we do not redraft claims to contradict their plain language in order to avoid a nonsensical result."  The Federal Circuit therefore concluded that the term "consistently means a vessel and a plurality of tubes."