Medtronic, Inc. v. Teleflex Innovations S.à.r.l., No. 21-2359 (Fed. Cir. 2023)
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For decades, cardiologists have used guide catheters to deliver interventional cardiology devices (e.g., guidewires, stents, balloon catheters) designed to alleviate stenoses. These procedures involved certain challenges and risks. Telex’s patents sought to address these problems by using a coaxial extension catheter insertable into standard guide catheters that offered increased backup support and the ability to deep seat without the attendant drawbacks of traditional systems.
Medtronic petitioned for inter partes review (IPR), alleging the challenged claims would have been obvious over prior art. The Patent Trial and Appeal Board found certain claims unpatentable. The Federal Circuit affirmed. The Board did not err in determining Medtronic failed to carry its burden to show that certain claims would have been obvious, and substantial evidence supports its underlying findings of fact. The court also upheld the Board’s determination that Telex's proposed Substitute Claims had adequate written description support and would not have been obvious over Medtronic’s asserted grounds.
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