Federal Circuit reverses District Court Summary Judgment Ruling on “Means plus Function” Claim

Posted by T. Williams on 02/26/08
Industry: Medical
Defendant: Stryker Corporation
Plaintiff: Trimed, Incorporated
Jurisdiction: Federal Circuit
Result: Summary Judgment Reversed
Source: Trimed, Incorporated v. Stryker Corporation, No. 2007-1327 (Federal Circuit, 2007)

Trimed, Incorporated successfully appealed a summary judgment ruling of non-infringement by the US District Court for the Central District of California. The Federal Circuit reversed and remanded the District Court decision finding that the District Court’s interpretation of “means plus function” was misapplied in the summary judgment ruling. The Federal Circuit stated that the Trimed patent claims articulated sufficient structure for performing the functions and therefore application of § 112 ¶ 6 was not appropriate.

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