## Facts

- Retractable Technologies, Inc. (RTI) owned patents covering retractable-needle safety syringes intended to reduce needle-stick injuries.
- RTI sued Becton, Dickinson and Company (BD), alleging BD’s “Integra” syringes infringed claims in U.S. Patent Nos. 5,632,733; 6,090,077; and 7,351,224.
- A central dispute concerned the meaning of the claim term “body” in the asserted syringe claims.
- The patent specifications repeatedly described the invention’s syringe “body” as a single piece and criticized prior art syringes with multi-piece (e.g., two-piece) bodies.
- All disclosed embodiments and figures depicted a one-piece body; the written description did not depict or describe multi-piece bodies as part of the invention.
- BD’s accused Integra syringes used a multi-piece body design.
- The district court construed “body” broadly to cover both one-piece and multi-piece bodies, and a jury found infringement and no invalidity; the court entered judgment for RTI and denied BD’s JMOL motions.

## Issues

1. Whether the claim term “body,” read in light of the specification, is limited to a one-piece syringe body or includes multi-piece bodies.
2. Whether the specification’s repeated description of a one-piece body and criticism of multi-piece prior art constitutes a limiting definition or disclaimer that narrows claim scope.
3. Whether claim differentiation prevents construing “body” narrowly where other claims expressly recite a “one piece body.”

## Decision

- The Federal Circuit adopted a narrower construction, holding “body” is limited to a one-piece body in view of the specification’s consistent characterization of the invention.
- The court rejected reliance on claim differentiation to broaden “body” beyond the scope indicated by the written description.
- Applying the narrowed construction, the court reversed infringement findings in part, concluding that at least BD’s 3 mL Integra syringe with a multi-piece body did not infringe the relevant claims.
- The court’s disposition altered the district court’s infringement judgment to the extent it depended on the broader “body” construction.

## Legal Principles

- Claim terms generally take their ordinary meaning, but that meaning must be determined in context, with the specification serving as the primary guide to what the patentee described as the invention.
- Repeated specification statements describing “the invention” in a particular way, especially when coupled with criticism or disparagement of alternatives, can narrow otherwise broader claim language.
- Claim differentiation is a useful interpretive tool but is not controlling and cannot expand claim scope beyond what the specification indicates is the invention.
- Courts may construe a claim term more narrowly than its linguistic breadth when the written description consistently limits the invention to a particular structure across embodiments and description.

## Conclusion

The Federal Circuit construed “body” to mean a one-piece syringe body based on the patents’ consistent description and disparagement of multi-piece designs, and it reversed the infringement judgment in part because BD’s multi-piece Integra syringes fell outside that narrowed claim scope.


Retractable Techs., Inc. v. Becton, Dickinson & Co., 653 F.3d 1296 (Fed. Cir. 2011)