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Becton, Dickinson & Co. v. Tyco Healthcare Group, LP

Tyco Healthcare Group, LP (“Tyco”) appeals a judg-ment of the United States District Court for the District of Delaware entered after a jury determined that Tyco’s Monoject Magellan™ safety needles and blood collection devices literally infringed claims 1-4, 6, 12, 13, 15, 24 and 27 of U.S. Patent No. 5,348,544 (the “’544 patent”). Be-cause we conclude that the district court incorrectly construed the “spring means” limitation of the asserted claims and erred in denying Tyco’s motion for judgment as a matter of law (“JMOL”), we reverse.

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