Vascular Solutions LLC v. Medtronic, Inc

Background

The plaintiffs, collectively called Teleflex, brought a patent-infringement lawsuit against the defendants, collectively called Medtronic. The patents concern a guide-extension catheter used to deliver interventional cardiology devices, such as balloons or stents, into a coronary artery. At this stage, Teleflex asserted claims 9, 13, and 18 of the ’032 patent, claim 4 of the ’413 patent, and claim 25 of the ’776 patent.

The disputed phrase was “substantially rigid portion/segment.” Some asserted claims place a side opening within that portion, while claim 25 of the ’776 patent places the side opening separately from and distal to it. In an earlier order, the court found the phrase indefinite and the claims invalid, after rejecting definitions proposed by the parties and an independent expert. The parties then stipulated to final judgment, and Teleflex appealed.

The Federal Circuit vacated that order and remanded for further claim construction. It held that the claims were not necessarily mutually exclusive merely because they described the side opening differently. It also held that “substantially rigid portion/segment” is a functional limitation: the relevant portion must be rigid enough to perform the function of allowing the device to advance within the guide catheter. The Federal Circuit instructed the district court to apply the construction across the patents while determining the portion’s boundary on a claim-by-claim basis.

Parties’ proposed constructions

Teleflex initially proposed “a longitudinal section that is rigid enough to allow the device to be advanced within the guide catheter.” It later proposed “the first proximal section of a multipart guide extension catheter that is rigid enough to allow the device to be advanced within the guide catheter.”

Medtronic proposed defining the term as the “pushrod that pushes the flexible tubular structure through the guide catheter.” As an alternative, Medtronic proposed “the first proximal part of a multipart guide extension catheter that is materially more rigid than and pushes the flexible tubular part within the guide catheter.” Neither party supported the independent expert’s earlier definition on remand.

Court’s analysis

The court concluded that Teleflex’s revised proposal best followed the Federal Circuit’s instructions. The court treated the term as functional rather than structural, because the definition describes what the portion must accomplish rather than specifying its materials or a fixed physical boundary. The phrase “first proximal section of a multipart guide extension catheter” also makes clear that the substantially rigid portion is one part of a multipart device, rather than the entire catheter.

The court rejected Medtronic’s “pushrod” definition. It found that the definition primarily described the portion by structure and that Medtronic had not provided a concrete meaning for “pushrod.” The court noted that, under the earlier analysis, nearly every portion of the device could be said to push another portion, leaving the term itself unclear.

The court also rejected the expert’s earlier definition because it was structural, specified a boundary that would not necessarily be consistent across claims, and could make some claims nonsensical. The court explained that the Federal Circuit’s guidance allowed the boundary to vary from claim to claim while requiring the same functional construction across the patents.

Ruling and schedule

The court construed “substantially rigid portion” as “the first proximal section of a multipart guide extension catheter that is rigid enough to allow the device to be advanced within the guide catheter.”

The court also ordered that initial expert disclosures and reports be served by July 25, 2025; rebuttal expert reports be served by August 22, 2025; and expert discovery be completed, with corresponding motions filed, by September 19, 2025. The court stated that it would revisit dispositive-motion deadlines after expert discovery and the filing of any motions. This order did not determine whether Medtronic infringed the patents.