Regents of the University of Michigan v. Leica Microsystems, Inc.
District Court
Holding
The Federal Circuit affirmed, holding that the claimed “said supercontinuum white light pulse” refers back to a “supercontinuum white light pulse comprising an entire spectrum of white light.” Because the accused products used discrete, selected wavelengths filtered from a white-light pulse before reaching the sample, they did not meet the claim limitation under that construction.
Why It Matters
The decision underscores that antecedent-basis language, claim differentiation within the same claims, specification statements, and prosecution distinctions over filtered discrete wavelengths can collectively lock a patentee into a narrower infringement theory.
Full Summary
Key Points
- The asserted independent claims required a “supercontinuum white light pulse comprising an entire spectrum of white light” that excites fluorophores in the sample.
- Michigan argued that the claims did not require the entire spectrum of white light to physically reach the sample; the Federal Circuit rejected that reading based on the plain claim language and the anaphoric effect of “said.”
- The court relied on claim language distinguishing the entire supercontinuum from a “portion” of the pulse, specification passages indicating the entire spectrum reaches the sample and rejecting filters, and prosecution statements distinguishing prior art that used discrete selected wavelengths.
- Because Michigan’s noninfringement appeal depended entirely on its proposed claim construction, the Federal Circuit affirmed once it adopted the district court’s construction.
- The court declined to review claim-construction issues not implicated by the judgment.
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