On Jan. 15, 2009, the Court of Appeals for the Federal Circuit invalidated a patent claim, reversing a district court determination that a defendant failed to show clear and convincing evidence that the claimed invention would have been obvious to a person of ordinary skill.  The Federal Circuit held the claimed stent obvious in view of a single prior art reference. The holding resulted from an analysis that concluded the reference did not show a single example stent that had all the limitations of the claim, but it showed two examples which, if combined, would have every limitation:

We agree with Cordis that one of ordinary skill in the art would have been motivated to combine the embodiment in figure 3B of Wolff with the embodiment in figure 4 of Wolff to arrive at a metal stent with two coating layers. Combining two embodiments disclosed adjacent to each other in a prior art patent does not require a leap of inventiveness.

Boston Scientific Scimend, Inc. v. Cordis Corp., CA No. 2008-1073, slip op. at 15-16 (Fed. Cir. January 15, 2009).

The Court characterized the prima facie showing of obviousness as "strong" and rejected an argument that the objective indicia of non-obviousness presented at trial overcame it. Id. at 16.