Laboratory Corporation of America Holdings v. Qiagen Sciences, LLC, Appeal No. 2023-2350 (Fed. Cir. Aug. 13, 2025)

In our Case of the Week, the Federal Circuit reversed a jury finding of infringement from the District of Delaware, holding that the jury’s findings and seven-figure damages award were not sufficiently backed by evidence.

Laboratory Corporation of America Holdings and affiliates sued Qiagen Sciences, LLC for infringement of Patent Nos. 10,017,810 and 10,450,597. After a five-day trial, the Delaware jury found that Qiagen willfully infringed the patents in suit, and that Qiagen failed to show that any of the claims at issue were invalid, awarding Laboratory Corporation roughly $4.7 million in damages. The District Court denied Qiagen’s motion for judgment as a matter of law after the jury’s damages finding. Qiagen appealed the denial of JMOL, on the basis that there was insufficient evidence to support the jury’s findings.

Regarding the ‘810 patent, Qiagen first argued that the jury should not have been allowed to apply plain meaning to conclude that “identical” meant the same thing as “identical to a portion.” Qiagen’s argument was that two sequences could not be identical simply because they shared an overlapping portion. Before trial, the District Court held that what constituted “identical” was an issue of fact for the jury, and the jury found that sequences under the ‘810 and the accused products were identical because a portion of the sequence in the accused product was identical to a portion of the sequence in the ‘810 patent, even if the sequences in their entireties were not identical. The Federal Circuit held it was error to leave claim construction to the jury, and, turning to dictionary definition, held that “[a]s a matter of claim construction, ‘identical’ cannot mean ‘identical to a portion’ because ‘identical’ means the same.” Second, Qiagen argued that there was insufficient evidence to support a finding of infringement under the doctrine of equivalents. The District Court agreed, finding there was insufficient evidence to satisfy any prong of the function-way-result test, because the evidence presented to the just was not “exceptional and [did] not rise to the level of ‘particularized testimony and linking argument’ showing substantial similarity between the accused products and asserted claims in function, way, or result.”

Similarly, regarding the ‘597 patent, the Federal Circuit agreed with Qiagen that there was insufficient evidence to support the accused products satisfied claims in the ‘597 patent.

Thus, the Federal Circuit reversed and remanded, with instructions that the District Court grant JMOL of non-infringement regarding both patents-in-suit.

The opinion can be found here.

By Tyler Hall

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Powerblock Holdings, Inc. v. IFit, Inc., Appeal No. 2024-1177 (Fed. Cir. Aug. 11, 2025)

In an appeal from the partial dismissal of an infringement claim based on patent ineligibility under 35 U.S.C. § 101, the Federal Circuit reversed.  At issue was PowerBlock’s U.S. Patent No. 7,578,771 directed to motorized adjustable dumbbells, most claims of which the district court had determined were directed to an abstract idea.  The Federal Circuit disagreed, explaining that claim 1 of the ’771 patent, while broad, “goes beyond claiming the broad concept of automating known technique and provides a sufficiently specific manner of performing automated weight stacking” (internal markings omitted).  Claim 1 is reproduced below:

1. 1. A weight selection and adjustment system for a selectorized dumbbell, which comprises:

(a) a selectorized dumbbell, which comprises:

(i) a stack of nested left weight plates and a stack of nested right weight plates;

(ii) a handle having a left end and a right end; and

(iii) a movable selector having a plurality of different adjustment positions in which the selector may be disposed, wherein the selector is configured to couple selected numbers of left weight plates to the left end of the handle and selected numbers of right weight plates to the right end of the handle with the selected numbers of coupled weight plates differing depending upon the adjustment position in which the selector is disposed, thereby allowing a user to select for use a desired exercise weight to be provided by the selectorized dumbbell; and

(b) an electric motor that is operatively connected to the selector at least whenever a weight adjustment operation takes place, wherein the electric motor when energized from a source of electric power physically moves the selector into the adjustment position corresponding to the desired exercise weight that was selected for use by the user.

Defendant iFit argued—and the district court had agreed—that because claim elements 1(a)(i)-(iii) simply recited a conventional adjustable dumbbell, the addition of limitation (b) amounted to claiming the abstract idea of motorizing such a device.  However, the Federal Circuit panel explained that it was improper to divide claims into “old” and “new” elements for purposes of a § 101 eligibility analysis, for which the claims must be considered as a whole.  Among other things, the panel observed that claim 1 is limited to a particular type of dumbbell and recites at least some limitations for how the claimed mechanism operates, e.g. that it is “operatively connected to the selector” and physically moves the selector.  Accordingly, the Court found that while reciting a “rather simple mechanical invention,” the claim was “limited to a specific implementation” of a purported technological improvement, and was not directed to an abstract idea.  The Federal Circuit reversed the district’s court’s decision and remanded for further proceedings.

The opinion can be found here.

By Jason A. Wrubleski

This article summarizes aspects of the law and does not constitute legal advice. For legal advice with regard to your situation, you should contact an attorney.