Federal Circuit Upholds Narrow Patent Claim Construction in Heart Valve Dispute
WASHINGTON D.C. – In a precedential ruling issued today, the U.S. Court of Appeals for the Federal Circuit (CAFC) largely affirmed a Delaware District Court’s decision in Aortic Innovations LLC v. Edwards Lifesciences Corp., concerning patent claims related to transcatheter heart valve technology. The ruling clarifies the extent to which a patent’s own specification can redefine claim terms, and reinforces the principle that such redefinition must be unequivocally clear.
The case centered on four patents (U.S. Patent Nos. 10881538, 10966846, 10987236, and 1129735) held by Aortic Innovations, alleging infringement by Edwards Lifesciences’ SAPIEN 3 Ultra valve. The core dispute revolved around the meaning of the claim term “outer frame” within the patents.
The District court had determined that Aortic Innovations, through consistent language within its patent specifications, had effectively redefined “outer frame” to mean “self-expanding frame.” This construction proved fatal to Aortic’s infringement claims, as the Edwards Lifesciences valve does not utilize a self-expanding frame.
[pullquote]”[S]tructures in the dual-frame embodiment disclosed by patent diagrams were interchangeably labeled as ‘outer frame’ and ‘self-expanding frame,’ a connection consistently repeated throughout the patents’ specification.”[/pullquote]
Aortic Innovations challenged this claim construction on appeal,arguing the District Court’s interpretation was too restrictive. Though, the CAFC sided with the lower court, finding that the patent specification’s consistent and interchangeable use of “outer frame” and “self-expanding frame” constituted a clear redefinition.
“Although a patent’s specification may define claim terms by implication… such implied redefinition must be so clear that it equates to an explicit one,” the court stated,referencing precedent set in Bell Atlantic Network Services v. Covad Communications (2001) and thorner v. Sony Computer Entertainment America (2012).
The CAFC also dismissed Aortic’s argument of judicial estoppel, finding no supporting case law was cited to substantiate the claim. Furthermore, the court ruled it lacked jurisdiction over claims related to the ‘538 patent, which had been invalidated by the U.S. Patent and Trademark Office in December 2023.
Implications for Patent Litigation:
this ruling underscores the importance of precise language within patent specifications. Patent holders can effectively narrow the scope of their claims by consistently defining terms in a specific manner throughout the document. Though,the CAFC’s decision emphasizes that this redefinition must be unambiguous and leave no room for choice interpretations.
For companies accused of patent infringement, the Aortic Innovations case provides a strong precedent for challenging claim constructions that rely on implied redefinitions lacking the necessary clarity.
Further Reading:
* CAFC Ruling: https://www.cafc.uscourts.gov/opinions-orders/24-1145.OPINION.10-27-2025_2593688.pdf
* U.S. Patent No. 10881538: [https://portalunifiedpatentscom[https://portalunifiedpatentscom[https://portalunifiedpatentscom[https://portalunifiedpatentscom
