## Facts

- Hill-Rom owned three related patents (U.S. Patent Nos. 5,699,038; 6,147,592; 7,538,659) covering systems that allow hospital personnel to remotely monitor hospital-bed status.
- The disclosed systems use bed sensors (e.g., patient presence, bed height) to generate bed-status data and transmit it to a remote processing station via a “datalink.”
- Hill-Rom sued Stryker, alleging Stryker’s hospital beds infringed asserted claims.
- Claim construction centered on four terms: (1) “datalink,” (2) “interface board including a processor,” (3) “message validation information,” and (4) “bed condition message.”
- The district court construed “datalink” to require a wired connection and adopted narrower constructions for the other terms, relying heavily on examples in the specification.
- Based on those constructions, the parties stipulated to noninfringement, and the district court entered summary judgment for Stryker.
- Hill-Rom appealed, arguing the constructions improperly narrowed the claims.

## Issues

1. Whether “datalink” should be limited to a wired connection or given its ordinary meaning that can include wired and wireless links.
2. Whether the district court improperly imported limitations from described implementations into the terms “interface board including a processor,” “message validation information,” and “bed condition message.”

## Decision

- The Federal Circuit reversed the summary judgment of noninfringement and remanded.
- The court held the district court erred by limiting “datalink” to wired connections absent a clear definition or clear and unmistakable disavowal.
- The court also rejected the district court’s narrowing constructions of the other disputed terms because the added structural and formatting requirements were not compelled by the claim language or intrinsic record.
- Because the noninfringement judgment rested entirely on the erroneous constructions, it could not stand.

## Legal Principles

- Claim terms generally receive their plain and ordinary meaning to a skilled artisan in view of the specification and prosecution history.
- Departure from ordinary meaning requires either (1) lexicography (a clear definitional statement) or (2) clear and unmistakable disavowal in the specification or prosecution history.
- Disclosure of a single embodiment, without clear limiting language, does not restrict the claims to that embodiment.
- Courts may not import features from preferred embodiments or examples into broader claim language without clear intrinsic evidence that the patentee intended to limit scope.

## Conclusion

The Federal Circuit corrected claim constructions that had confined broadly worded terms to particular disclosed implementations, reversed the resulting stipulated noninfringement judgment, and remanded for further proceedings under constructions consistent with ordinary meaning absent lexicography or disavowal.


Hill-Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367 (Fed. Cir. 2014)