Case Explained: MEDMIX SWITZERLAND AG v. SQUIRES

Court: United States Court of Appeals for the Federal Circuit Filed: 2026-06-15 The Federal Circuit affirmed the Patent Trial and Appeal Board’s final written decision holding that claims 1–3, 9–13, and 16–17 of U.S. Patent 9,010,578 are unpatentable as obvious under 35 U.S.C. § 103. The court reviewed the Board’s claim construction de novo and its factual findings regarding motivation to combine prior art references for substantial evidence. Regarding claim construction, the court held that the term “at least two ramps” does not require an “inclined plane” shape. Applying the principles of *Phillips v. AWH Corp.*, the court found that neither the plain language of the claims nor the specification explicitly limited the ramps to a specific shape; rather, the specification described the figures as “preferred illustrative embodiments” and did not clearly indicate an intent to limit the claims to that specific geometry. The court further rejected Medmix’s argument based on prosecution history, determining that the amendment adding the “ramps” limitation was intended to distinguish prior art regarding axial guidance during connection and release, not to impose a shape restriction. Regarding obviousness, the court found substantial evidence supporting the Board’s conclusion that a person of ordinary skill in the art would have been motivated to combine U.S. Patents 6,769,574 (Keller) and 6,161,730 (Heusser) with Canadian Patent 1,238,023 (Yu). The Board found that incorporating Yu’s coarse thread connection provided mechanical advantages by reducing the axial force required to detach the device in Keller or reducing the number of rotations needed for Heusser. The court rejected Medmix’s argument that potential back-pressure and leakage issues dissuaded such a combination, noting that the Board explicitly found these concerns could be easily mitigated using “tangs” and “flanges.” Consequently, the patent claims remain invalid, and the patentee cannot enforce them against infringers. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.