Medtronic Minimed v. Animas Corp.

When a patent involves mean-plus-function language the terms must be capable of being comprehended by an expert within that field in order to be held invalid for indefiniteness.

Opinion (Ronald): Plaintiffs Medtronic Minimed Inc., Medtronic Puerto Rico Operations Co., and Minimed Distribution Corp. (collectively 'Medtronic') and Defendant Animas Corp. produce and sell insulin pumps for Type I diabetics. Animas Corp. recently produced an insulin delivery system titled the OneTouch System. The patent at issue in this case is Medtronic's ‘065 patent, which describes the insulin pump’s three delivery settings. Medtronic claimed that Animas Corp. infringed upon it’s ‘065 patent by producing and selling the OneTouch System. It is undisputed that the '065 patent incorporates means-plus-function language. Mean-plus-function language “must describe in the patent specification some structure which performs the specified function.” Additionally, the means-plus-function language must describe the structure that performs the patented function in terms that are capable of being comprehended by an expert within that field. Animus claimed that the mean-plus-function language in the ‘065 patent was insufficient because it failed to describe the algorithm or software that is used to execute the patented functions. Rather the ‘065 patent designates the “controller” as the structure by which the insulin pump carries out the claimed functions for all three delivery settings. The court held that the mean-plus-language in each limitation was not invalid for indefiniteness because an artisan would understand the description of the controller and its connection to the claimed functions. Motion for partial summary judgment filed by Defendants was DENIED.