Reliance on specification to interpret disputed claim term is appropriate

In ICU Medical, Inc. v. Alaris Medical Systems, Inc., Fed. Cir., No. 2008-1077, March 13, 2009, the Federal Circuit affirmed a decision of the U.S. District Court for the Central District of California holding that (i) claims 11, 12, and 16 of U.S. Patent No. 6,572,592 (the '592 patent), claims 1, 3, 4, 6, and 7 of U.S. Patent No. 5,685,866 (the '866 patent), and claims 1 and 2 of U.S. Patent No. 5,873862 (the '862 patent) were not infringed and (ii) claims 17-26, 31-42, and 46 of the '592 patent and claims 11-16 of U.S. Patent No. 6,682,509 (the '509 patent) were invalid for failure to satisfy the written description requirement.