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This case turned entirely on the construction of terms in asserted claim 21.  The district court granted Medtronic’s motion for summary judgment of non-infringement of claim 21 and granted Atlas’ motion for summary judgment that claim 21 was neither anticipated nor obvious.  The patent related to preserving battery power in systems for controlling wireless network communications between a hub and remotes. 

The court first affirmed the non-infringement finding, holding that the district court’s construction of the “establishing” and “transmitting” clauses that required the endpoint of the communication cycle is communicated to the remotes before any remote transmits frames to the hub.  This construction was supported by the claims and the specification, and the doctrine of claim differentiation was inapplicable, because, under the court’s construction, the dependent claims were not superfluous. 

The court next reversed the grant of summary judgment of no anticipation or obviousness, due to an erroneous claim construction.  The district court, relying on “plain meaning,” held that “the hub and the remotes transmit and receive frames during each communication cycle.”  The court first addressed the ambiguity of the court’s construction, because it was unclear whether all or some, or even how many, remotes transmit.  The court held that the “plain meaning” attributed the terms by the district court, was incorrect, because it ignored the context provided by the remainder of the claims and the specification.  The district court improperly relied on the claim words in isolation from the claims and the specification.  Under the proper construction, there are intervals in which remotes are permitted  to transmit frames, and therefore the grant of summary judgment on the validity issues was incorrect and reversed.

Atlas IP, LLC v. Medtronic, Inc., Case Nos. 2015-1071, -1105 (October 29, 2015); Opinion by: Taranto, joined by Moore and Reyna; Appealed From: District Court for the Southern District of Florida, Altonaga, J.  Read the full opinion here.

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