Contract analysis

I. INTRODUCTION Plaintiff Apex Surgical Innovations, Inc. ("Apex") filed this patent infringement action on May 9, 2024, alleging that Defendant Solstice Biomedical, Inc.'s ("Solstice") PrecisionEdge™ line of laparoscopic trocar assemblies — specifically, the PE-5000, PE-12000, and PE-15000 Series — infringes three Apex utility patents directed to components and subsystems of minimally invasive surgical access device

1. U.S. Patent No. 9,814,237 ("the '237 Patent"), entitled "Locking Seal Assembly for Minimally Invasive Surgical Access Device," which issued on November 14, 2017, and is set to expire on June 22, 2035. Apex asserts Claims 1, 3, 7, and 12 of the '237 Patent.

2. U.S. Patent No. 10,271,884 ("the '884 Patent"), entitled "Retractable Blade Deployment Mechanism for Trocar Systems," which issued on April 30, 2019, and is set to expire on September 15, 2036. Apex asserts Claims 1, 2, 5, 9, and 14 of the '884 Patent.

3. U.S. Patent No. 10,932,105 ("the '105 Patent"), entitled "Integrated Insufflation Valve and Seal for Laparoscopic Trocar," which issued on March 2, 2021, and is set to expire on January 10, 2038. Apex asserts Claims 1, 4, and 8 of the '105 Patent. The named inventor on all three asserted patents is Dr. Raymond Szabo, who serves as Vice President of Engineering at Apex Surgical Innovations, Inc. All three patents a

II. LEGAL STANDARD A. Claim Construction Principles Claim construction is a matter of law for the Court. Markman v. Westview Instruments, Inc., 52 F.3d 967, 979 (Fed. Cir. 1995) (en banc), aff'd, 517 U.S. 370 (1996). The purpose of claim construction is to determine the meaning and scope of the patent claims, which define the boundaries of the patentee's right to exclude. Id. at 976. The Federal Circuit's en banc dec

III. TECHNOLOGY BACKGROUND A. Laparoscopic Trocar Systems Generally Laparoscopic surgery — also known as minimally invasive surgery — is a surgical technique in which operations are performed through small incisions (typically 5 to 15 millimeters in length) rather than the larger incisions required in traditional open surgery. Laparoscopic procedures offer significant advantages over open surgery, including reduced p

IV. CONSTRUCTION OF THE DISPUTED CLAIM TERMS A. Disputed Terms from the '237 Patent ("Locking Seal Assembly for Minimally Invasive Surgical Access Device") 1. "locking seal assembly" (Claims 1, 3, 7, 12). Apex's Proposed Construction: "A seal assembly that is held in a fixed position." Solstice's Proposed Construction: "A seal assembly comprising an elastomeric seal element and a mechanical locking interface that pos