Background
C.R. Bard, Inc. and Bard Peripheral Vascular, Inc. sued Medical Components, Inc. in the District of Utah, alleging infringement of patents concerning systems and methods for identifying whether a venous access port is power injectable. The district court initially held the asserted claims patent-ineligible under 35 U.S.C. § 101, but the Federal Circuit reversed and remanded based on its decision in related litigation involving AngioDynamics, Inc.
On remand, MedComp sought summary judgment that Bard’s claims were anticipated by U.S. Patent No. 6,287,293, known as Jones. The district court denied the motion, concluding that limitations such as “power injectable” and “suitable for power injection” described the port’s functionality rather than merely printed matter. Because the Jones device was not power injectable, the court found that Jones did not anticipate the asserted claims. After reconsideration was denied, MedComp petitioned for mandamus directing the district court to hold the claims invalid.
The Court’s Holding
The Federal Circuit denied the petition. It emphasized that mandamus is a drastic and extraordinary remedy requiring, among other things, a clear and indisputable right to relief and no other adequate means of obtaining it.
MedComp argued that the district court violated the Federal Circuit’s mandate by giving patentable weight to the disputed limitations, relying on the court’s earlier AngioDynamics II decision. The Federal Circuit rejected that basis for extraordinary relief, explaining that this case was unlike authority permitting mandamus to enforce an appellate mandate entered in the same proceeding. AngioDynamics II arose from separate litigation, so MedComp had not established grounds for mandamus compelling an invalidity judgment.
Key Takeaways
- The Federal Circuit refused to use mandamus to compel the district court to find Bard’s asserted patent claims anticipated.
- A decision or mandate issued in separate litigation does not support mandamus in the same manner as a mandate entered in the proceeding before the court.
- The order leaves intact the district court’s ruling that the disputed “power injectable” limitations describe port functionality and that Jones does not anticipate the claims.
Why It Matters
The nonprecedential order underscores the narrow role of mandamus in patent litigation. A party generally cannot use an extraordinary writ to obtain immediate review of a summary-judgment denial merely by characterizing the ruling as inconsistent with an appellate decision from a different case.
The merits of Bard’s infringement claims and MedComp’s invalidity defense remain for further proceedings in the District of Utah, subject to review through the ordinary appellate process after final judgment.