Court: U.S. Court of Appeals for the Federal Circuit

Docket: 23-2350 

Opinion Date: August 13, 2025

The case concerns two patents related to methods for preparing DNA samples for sequencing, owned by Laboratory Corporation of America Holdings, Labcorp Genetics, Inc., and The General Hospital Corporation. The patents describe techniques for enriching specific regions of DNA to make sequencing more efficient, using various types of primers and adaptors. The dispute centers on whether certain DNA preparation kits sold by Qiagen and its affiliates infringe these patents, specifically regarding the design and function of the primers used in Qiagen’s kits.

After the plaintiffs filed suit in the United States District Court for the District of Delaware, alleging infringement of both patents, the case proceeded to a jury trial. The jury found that Qiagen willfully infringed the asserted claims of both patents—under the doctrine of equivalents for one patent and literally for the other—and awarded the plaintiffs approximately $4.7 million in damages. The district court denied Qiagen’s renewed motion for judgment as a matter of law (JMOL) on non-infringement, invalidity, and damages, and also denied Qiagen’s alternative request for a new trial.

On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL de novo. The Federal Circuit held that there was insufficient evidence to support the jury’s findings of infringement for either patent. The court determined that the district court erred in allowing the jury to interpret the claim term “identical” as “identical to a portion,” and found that the evidence did not support infringement under the doctrine of equivalents or literal infringement as required by the patent claims and their constructions. As a result, the Federal Circuit reversed the district court’s denial of JMOL of non-infringement for both patents, and remanded with instructions to grant JMOL of non-infringement.