The following is a summary of the precedential patent-related opinions issued by the Court of Appeals for the Federal Circuit for the week ending May 2, 2014. Ross Barton prepared this edition.
Case Summaries
Claim Interpretation: Ordinary Meaning
Claim Interpretation: Intrinsic Evidence: Importing Limitations from the Specification into Claims
Claim Interpretation: Intrinsic Evidence: Preferred Embodiments
Litigation Practice and Procedure: Procedure: Summary Judgment: Summary Judgment Procedure
GE Lighting Solutions, LLC v. AgiLight, Inc., No. 13-1267 (Fed. Cir. (N.D. Ohio) May 1, 2014). Opinion by Moore, joined by Rader. Opinion concurring-in-part and dissenting-in-part by Reyna.
In reversing and remanding the district court’s grant of summary judgment that the accused products do not infringe the asserted device claims, the Federal Circuit ruled that the district court incorrectly construed the claims at issue. With regard to the process claims at issue, however, the Federal Circuit affirmed the district court’s grant of summary judgment.
GE Lighting Solutions, LLC sued AgiLight, Inc. (“AgiLight”), alleging infringement of U.S. Patent Nos. 7,160,140 (“the ’140 patent”), 7,520,771 (“the ’771 patent”), 7,832,896 (“the ’896 patent”), and 7,633,055 (“the ’055 patent”), each of which relates to LED string lights. With regard to the ’140 and ’771 patents, the district court construed the claim term “IDC connector” to include four electrical terminals and a housing that encloses three insulated conductors, relying on a figure from the specification and two dependent claims. The Federal Circuit concluded that the district court erred in its construction of this term. In the Federal Circuit’s view, the district court’s construction was in conflict with the plain and ordinary meaning of “IDC connector,” i.e., “a connector that displaces insulation surrounding an insulated conductor to make electrical contact with the conductor.” The Federal Circuit thus determined that, in the absence of clear language of disavowal, it was error to import the structural limitations of the preferred embodiment and the dependent claims into the term “IDC connector.”
With regard to the ’896 patent, the Federal Circuit determined that the district court erred in its construction of certain terms describing an optical element. The first issue was whether the entire “inner profile” of the optical element must be “substantially ellipsoidal” or whether the claims can be satisfied if merely a portion of the “inner profile” is “substantially ellipsoidal.” The Federal Circuit noted that the only embodiment depicted was an optical element in which only a portion of the inner profile is ellipsoidal. Because claims should not be construed in a manner that would exclude the preferred embodiment, especially where there is only one disclosed embodiment, the Federal Circuit concluded that the district court’s claim construction that required the entire inner profile to be substantially ellipsoidal was erroneous. Similarly, the Federal Circuit determined that the limitation requiring the optical element to have a “generally spherical” outer profile was improperly construed for similar reasons. In view of the erroneous claim constructions, the Federal Circuit reversed the grant of summary judgment and remanded.
With regard to the ’055 patent, the Federal Circuit affirmed the district court’s ruling of noninfringement based on the construction of the term “annular gasket.” At issue were certain claims directed to an overmolding process that utilizes an annular gasket to protect an LED on a circuit board from the sealant. On appeal, the Federal Circuit agreed with the district court that AgiLight’s dome-shaped lens is not an annular gasket because it does not have “an opening.” The court stated that this is consistent with the plain and ordinary meaning of a “gasket” and the description of an annular gasket in the ’055 patent.
In an opinion dissenting-in-part, Judge Reyna disagreed with the interpretation of the terms “substantially ellipsoidal inner profile” and “generally spherical outer profile” in the ’896 patent. In view of several statements in the patent that Judge Reyna considered to be expressly ambiguous, he would have found in favor of a construction that favors the public rather than the patentee.
http://www.cafc.uscourts.gov/images/stories/opinions-orders/13-1267.Opinion.4-28-2014.1.PDF
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