The Federal Circuit upheld a district court's decision in Alnylam Pharmaceuticals' patent infringement case against Moderna, focusing on the precise definition of claim terms in patents. The court reinforced the principle that clear definitions within a patent specification set challenging standards for establishing exceptions. The dispute centered around the term "branched alkyl" in Alnylam's patents for lipid technology, which Modern appeared to have used in their COVID-19 vaccine. Ultimately, the court found that Alnylam failed to demonstrate any exception to the explicit definition that would support their infringement claims.
"When a patent specification clearly defines a claim term, the patentee faces a demanding standard to establish exceptions to that definition, even if it conflicts with other parts of the specification."
"The case centered on whether Alnylam's patents covering cationic lipids for nucleic acid delivery were infringed by Moderna's use of the SM-102 lipid in its SPIKEVAX COVID-19 vaccine."
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