Colibri Heart Valve LLC v. Medtronic CoreValve, LLC, No. 23-2153 (Fed. Cir. July 18, 2025)

Editorial Summary

AI-assisted editorial summary; not attorney-reviewed. Verify against the opinion itself before relying on any characterization of the holding.

Colibri won a Central District of California jury verdict that Medtronic infringed claim 1 of U.S. Patent No. 8,900,294, directed to a method of implanting an artificial heart valve, under the doctrine of equivalents. The Federal Circuit reversed the denial of Medtronic's JMOL motion, holding that prosecution history estoppel barred Colibri's doctrine-of-equivalents theory: Colibri's cancellation of an independent claim during prosecution effected a narrowing surrender, and a skilled artisan reading the prosecution history would understand that the surrendered territory could not be recaptured. The reversal mooted Medtronic's remaining invalidity, non-infringement, and damages arguments.