Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc. (13-854)

argument 13-854

Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc.

Supreme Court of the United States 58 min 5 speakers 8 chapters transcribed 6 days ago official recording ↗
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What is the central dispute in Teva Pharmaceuticals v. Sandoz and why does claim construction matter?

John G. Roberts 0:01
We'll hear argument first this morning in case thirteen eight fifty four Tiva Pharmaceuticals versus Sandoz. Mr J?
Donald B. Verrilli Jr. 0:09
Mr Chief Justice, and may it please the Court, in our judicial system, the trial judges find the facts. Courts of appeals review those fact findings deferentially under Rule fifty two. The federal courts apply that familiar standard. even whenever the ultimate question is one of law, but it rests on subsidiary fact finding. Now the Federal Circuit says that claim construction is different, that there are no facts in claim construction. But more than a hundred years of practice from this court makes clear that that's not right. Facts can enter claim construction, and they do so when the trial judge does what this court has instructed her to do. To find what a person of skill in the art already knows.
Donald B. Verrilli Jr. 0:46
as relevant to interpreting the patent.
Unknown 0:49
this case and tell tell us what are the facts to which the Federal Circuit should have applied clearly erroneous rule.
Donald B. Verrilli Jr. 0:59
Certainly, Justice Ginsburg, there are three in our view. The first is that the Federal the Federal Circuit failed to defer to the trial court's finding about the presumed meaning of the term average molecular weight in the in the relevant context. The second is that the tri federal circuit failed to defer to what the uh district court expressly found resolving an expert dispute was the import of figure one and where the peak of the curve in figure one appears. And the third is how a person of ordinary skill in the art would have read a piece of the prosecution history. So if I may, I'll begin with why the uh uh the reference to average molecular weight in the patent and the and the specific reference to size exclusion chromatography, the particular technology being used to find that, fits the rule that we're asking this court to adopt.
Unknown 1:55
It's whether a a skilled artisan would make this inference. Is that part of the finding?
Donald B. Verrilli Jr. 2:01
Part of the finding is the knowledge of a skilled artisan, that's right. Sometimes th sometimes the the finding is just about pure science. How an invention works what this court called it in the Wynans versus New York and Erie case is terms of art or the state of the art. And the way the state of the art can enter the analysis is when you're using science to construe the patent. So for example, at this temperature the invention would work. At that temperature, the invention would not work. Therefore the temperature must be felt s Celsius and not Fahrenheit, for example. When you do that, uh when you're using science and not words or structure as the as as an interpretive guide. That rests on fact finding just as much as uh the as knowing the meaning of terms of art to people with skill in the art does.
Donald B. Verrilli Jr. 2:47
Now the terms of art has a lengthy pedigree in this court's cases. Not just in patent cases, although it's certainly strong in patent cases as well, but in the interpretation of other written instruments, the the meaning of terms of art in a community to which an interpretive community to which the trial judge does not belong is exactly the kind of thing that trial judges need the input from experts to determine.
Samuel A. Alito 3:10
Well that's not true of terms of art in statutes, is it?
Donald B. Verrilli Jr. 3:13
Terms of art and statutes, Justice Alito, are not are nonetheless written to be read by the general public. And what when they have uh when they have a legal meaning, the determination of that legal meaning is still a question of law. But
Samuel A. Alito 3:26
some of them are very technical. And I doubt that the the general public has any understanding of some very technical terms that appear in statutes. So would they not be read in light of what someone who is knowledgeable in that field would understand the the term to mean?
Donald B. Verrilli Jr. 3:42
I think it is very rare for Congress to adopt statutes that have tur that have terms that are meant to be read by a specialized audience like the question. I'll give you an example.
Samuel A. Alito 3:51
The Dodd-Frank Act refers to Tier I capital. Do you think that the average person on the street has any idea what Tier I capital is?
Donald B. Verrilli Jr. 4:00
I I I expect that it has an established meaning, but I although I certainly don't know for sure uh

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