Federal Circuit Affirms Implicit Redefinition of Claim Terms

In Aortic Innovations LLC v. Edwards Lifesciences Corp., No. 2024-1145 (Fed. Cir. Oct. 27, 2025), the Federal Circuit affirmed a district court’s construction of the term “outer frame” as “a self-expanding frame” based on implicit lexicography.

Aortic sued Edwards Lifesciences, asserting four patents related to transcatheter valves for treating aortic diseases. The district court determined that the patentee had acted as his own lexicographer to redefine the term “outer frame” by using the terms “outer frame,” “self-expanding frame,” and “self-expanding outer frame” interchangeably. Following this construction, the parties stipulated to noninfringement and Aortic appealed the district court’s claim construction.

On appeal, the Federal Circuit affirmed the district court’s construction, finding that the patent clearly and consistently demonstrated that that the “outer frame” must be self-expanding. The Federal Circuit also rejected Aortic’s argument that Edwards asserted plain and ordinary meaning of the term in a parallel IPR proceeding and thus should be estopped from arguing for a different construction here. The Court found that Aortic forfeited this estoppel argument by failing to raise it at the district court.