Case Explained: BERALL v. TELEFLEX MEDICAL INC

Court: United States Court of Appeals for the Federal Circuit

Filed: 2026-07-02

The Federal Circuit affirmed the district court’s transfer of a patent infringement case from the Southern District of New York to the Eastern District of North Carolina and its grant of summary judgment of noninfringement. The court reviewed the district court’s claim construction de novo, adopting the interpretation that the term “mounted on” in U.S. Patent No. 5,827,178 means “fastened to the exterior of.” This construction was based on the intrinsic evidence, specifically the patent’s use of contrasting prepositions where “mounted on” is used for the camera and screen while “mounted in” is used for the power supply, indicating a distinction between exterior and interior attachment. Regarding summary judgment, the court applied Fourth Circuit standards to review the noninfringement ruling. It found no genuine issue of material fact for literal infringement because the accused device’s camera was fastened to the interior of the blade, not the exterior as required by the claim construction. For infringement under the doctrine of equivalents, the court affirmed the lower court’s decision that the patentee failed to meet specific evidentiary requirements, noting that Dr. Berall did not provide limitation-specific arguments or particularized testimony regarding the insubstantial differences or function-way-result tests in his summary judgment briefing. Finally, the court held that the district court did not abuse its discretion in rejecting Teleflex’s waiver or forfeiture of its venue objection; under Federal Rule of Civil Procedure 25(c), Teleflex was acting solely as LMA’s successor-in-interest during earlier proceedings and had not waived its right to contest venue until it was sued separately for its own products. As a result, the patent infringement suit against Teleflex Medical Inc. is dismissed with respect to the accused products, and the case remains transferred to the Eastern District of North Carolina where the noninfringement judgment stands.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.