Background
Medmix Switzerland AG owns a patent for a device that mixes and discharges fluids using a cartridge and a mixer connected by a device with guide grooves and ramps. Xinial Systems GmbH petitioned for inter partes review, arguing the patent claims were obvious over three prior patents. The Patent Trial and Appeal Board agreed, construing the term at least two ramps to not require a specific shape and finding a motivation to combine the references based on mechanical advantages.
The court’s reasoning
The court reviewed the Board’s claim construction de novo and found the plain language of the claims and specification did not limit ramps to an inclined plane shape. The court also found the Board’s motivation-to-combine finding supported by substantial evidence, as the Board identified ways to mitigate potential back-pressure issues that Medmix argued would dissuade a skilled artisan from combining the references.
What it means going forward
The decision reinforces that patent claim terms are defined by their plain language and that the Board’s factual findings regarding motivation to combine references will be upheld if supported by substantial evidence, even when the patent owner argues about potential disadvantages of combining references.