Federal Circuit Reverses PTAB’s Invalidation of Patent Claims for an Artificial Heart Valve (Snyders vs St. Jude)

| Printer friendly version

On October 5, 2021, the U.S. Federal Circuit reversed a finding of invalidity by the Patent Trial and Appeal Board (PTAB) for patent claims related to an “artificial valve for repairing a damaged heart valve.”  St. Jude Medical LLC (“St. Jude”) filed for an inter partes review (IPR) at the PTAB for U.S. Patent No. 6,821,297, entitled “Artificial Heart Valve, Implantation Instrument and Method Therefor,” owned by Snyders Heart Valve LLC (“Snyders”).

In invalidating the claims, the PTAB interpreted the patent claim limitation of a “frame sized and shaped for insertion between the upstream region and the downstream region.”  The PTAB found that the limitation also covers a frame that fits in place after removal of a damaged heart valve.  The cited prior art allegedly also disclosed a valve insert sized to fit the valve after the damaged native valve was removed.  Therefore, the PTAB found that the prior art anticipated the claims.

The Federal Circuit held that the PTAB erred in determining that the “sized and shaped” limitation “does not require the frame be sized and shaped for insertion into a damaged heart valve,” but “only that the frame is sized and shaped for insertion in a position between the upstream region and the downstream region.”  The Federal Circuit reasoned that the PTAB’s construction was incorrect because “it covers frames sized and shaped for installation with the native valve removed, rather than only with the native valve in place.”  The Federal Circuit cited language in the patent specification allegedly stressing that the disclosed artificial heart valve can be inserted without removing the native valve, an alleged express improvement on the prior art.

The Federal Circuit’s decision is available here.

Nima Zargari
Nima uses his degrees, training, and experience to give clients thorough and diligent legal and professional advice, providing structured solutions to their intellectual property needs. Nima received his J.D. from Loyola Law School, Los Angeles, where he worked in the Ninth Circuit Appellate Clinic, and successfully briefed a withholding of removal immigration case to the U.S. Court of Appeals for the Ninth Circuit. He also served as the editor-in-chief of Volume 40 of the Loyola of Los Angeles Entertainment Law Review. Before attending law school, Nima earned his Ph.D. in chemistry from the University of Southern California. His graduate work focused on small molecule synthesis via palladium(II) catalysis. Nima worked as a summer associate with the firm in 2019 and joined the firm in 2021.
View all posts published by Nima Zargari »

Leave a Reply

By using this blog, you agree and understand that no information is being provided in the context of any attorney-client relationship. You further agree and understand that nothing herein is intended to be legal advice. This blog is solely informational in nature, and is not intended as, and should not be used as, a substitute for competent legal advice from a retained and licensed attorney in your state. Knobbe Martens LLP makes no representations or warranties as to the accuracy, completeness, timeliness or availability of the information in this blog. Knobbe Martens LLP will not be liable for any injury or damages relating to your use of, or access to, any such information. Knobbe Martens LLP undertakes no obligation to correct or update information on this blog, which may be incorrect or become incorrect or out of date over time. Knobbe Martens LLP reserves the right to alter or delete content or information on the blog at any time. This blog contains links and references to other websites and publications that you may find of interest. Knobbe Martens LLP does not control, promote, endorse or otherwise have any affiliation with any other websites or publications unless those websites or publications expressly state such an affiliation. Knobbe Martens LLP further has no responsibility for, and makes no representations regarding, the content, accuracy or any other aspect of the information in such websites or publications.