SciMed Life Systems, Inc. v. Advanced Cardiovascular Systems, Inc.
United States Court of Appeals for the Federal Circuit
242 F.3d 1337 (2001)
SciMed's (plaintiff) three patents covered balloon dilation catheters using a coaxial lumen configuration, with the specification repeatedly emphasizing that coaxial (rather than dual) lumens were superior in reducing shaft size and increasing flexibility, and stating that the coaxial structure was the basic structure for all embodiments the patents contemplated. SciMed sued ACS (defendant) for infringement based on ACS's dual-lumen catheters; the district court granted ACS summary judgment, finding the patent claims limited to coaxial lumens (so no literal infringement) and that the dual-lumen catheters were too dissimilar for any reasonable jury to find infringement under the doctrine of equivalents either.
Whether, under the specific exclusion rule, the doctrine of equivalents may be applied to bring within the reach of a patent subject matter specifically excluded by the patent's claims or specification.