Solventum Corp v. Wound HeALing Technologies Corp

1. Case Identification

• Case #: IPR2025-01042
• Patent #: 10,639,404
• Filed: June 13, 2025
• Petitioner(s): Solventum Corporation
• Patent Owner(s): Wound Healing Technologies, LLC
• Challenged Claims: 1-13

2. Patent Overview

• Title: Wound Dressing
• Brief Description: The ’404 patent discloses wound dressings for administering negative pressure wound therapy (NPT). The alleged invention combines conventional NPT components, such as a drain and a fluid-absorbing layer, with a vapor sealant sheet formed from a hydrocolloid material to purportedly reduce the complexity of wound preparation.

3. Grounds for Unpatentability

Ground 1: Obviousness over Argenta and Hu - Claims 1-7, 11, and 13 are obvious over Argenta in view of Hu.

• Prior Art Relied Upon: Argenta (Application # 2008/0208147) and Hu (Application # 2010/0042021).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Argenta disclosed a conventional NPT dressing with all limitations of the independent claims except for the vapor sealant sheet being "formed from a hydrocolloid material." Argenta taught a wound dressing with a drain (e.g., a Jackson-Pratt drain), a vacuum tube, a fluid-absorbing screen (made of foam or gauze), and an overlying adhesive cover. Petitioner asserted that Hu explicitly taught an NPT device where the sealant layer is "made of a hydrocolloid material" to cover a wound and distribute pressure. The combination of Argenta's dressing with Hu's hydrocolloid cover allegedly rendered the claims obvious. Dependent claims reciting gauze or foam layers were also disclosed by Argenta's screen material.
  • Motivation to Combine (for §103 grounds): A Person of Ordinary Skill in the Art (POSA) would combine Hu's hydrocolloid cover with Argenta's NPT dressing to gain the well-known benefits of hydrocolloids. These benefits included protecting the periwound skin from moisture damage, optimizing the moist wound environment for better healing, and easier, more reliable application compared to standard film drapes which could adhere to themselves.
  • Expectation of Success (for §103 grounds): A POSA would have had a reasonable expectation of success, as hydrocolloid dressings were standard, well-understood components used in wound care for decades and were one of a finite number of predictable solutions for covering a wound.

Ground 2: Obviousness over Argenta, Hu, and Biggie - Claims 8-10 are obvious over Argenta in view of Hu and Biggie.

• Prior Art Relied Upon: Argenta (Application # 2008/0208147), Hu (Application # 2010/0042021), and Biggie (Patent 7,520,872).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Argenta and Hu to address claims 8-10, which require the vacuum/drainage tube to have a "plurality of lumens." Petitioner contended that Biggie explicitly disclosed a multi-lumen tube for use in NPT. Biggie taught using one lumen for applying negative pressure and a secondary lumen for supplying medications or inserting other medical devices, such as electrical conductors for stimulus or heat treatment.
  • Motivation to Combine (for §103 grounds): A POSA would incorporate Biggie's multi-lumen tube into the Argenta/Hu NPT dressing to add the simple, known improvement of providing a dedicated channel for delivering medication or other fluids without disturbing the wound dressing. This added versatility and functionality, addressing a known need in wound care.
  • Expectation of Success (for §103 grounds): Combining a standard multi-lumen tube with a standard NPT dressing was a straightforward and predictable modification for a POSA.

Ground 3: Obviousness over Argenta, Hu, and Lockwood - Claims 1, 4-7, and 12 are obvious over Argenta in view of Hu and Lockwood.

• Prior Art Relied Upon: Argenta (Application # 2008/0208147), Hu (Application # 2010/0042021), and Lockwood (Application # 2005/0131327).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed any potential deficiency in Argenta/Hu regarding the limitation that the drain be "configured to non-simultaneously withdraw fluid from a wound and deliver fluid to the wound" (claim 1) and the requirement of a "plurality of NPT drains" (claim 12). Petitioner argued that Lockwood expressly disclosed a system with a switch valve to toggle between a vacuum source and an irrigation source, thus enabling non-simultaneous withdrawal and delivery of fluid through the same tube. Lockwood also taught using a plurality of ports or branched tubes to more evenly distribute suction, meeting the plurality of drains limitation.
  • Motivation to Combine (for §103 grounds): A POSA would add Lockwood's switch valve to the Argenta/Hu combination to implement well-known instillation therapy, which involves delivering medication and allowing it to dwell before withdrawal. A POSA would also incorporate Lockwood’s multi-drain configuration to achieve more uniform distribution of negative pressure, a stated goal of Argenta's own design.
  • Expectation of Success (for §103 grounds): Incorporating a simple switch valve and branching the distal end of a tube were routine modifications that a POSA would have expected to work as intended.

4. Key Claim Construction Positions

• "tube-anchorage" and "tube-exit-sealant" components: Petitioner argued that for the purposes of the IPR, these terms should be given their plain and ordinary meaning, as the Patent Owner forcefully argued during prosecution. This position contrasted with the Examiner's previous construction of the terms as means-plus-function limitations under 35 U.S.C. §112(f).
• "NPT drain being configured to non-simultaneously withdraw fluid from a wound and deliver fluid to the wound": Petitioner proposed construing this phrase to mean "an NPT drain capable of non-simultaneously withdrawing fluid from a wound and delivering fluid to the wound." This construction does not require a special structure, only that the drain is not actively prevented from performing both functions, such as by a one-way valve.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of Patent 10,639,404 as unpatentable.