June 17, 2016

Federal Circuit Court Decisions For Week Ending June 3, 2016

Eveready Battery Co. v. Spectrum Brands, Inc., No. 2015-1824, May 31, 2016 (non-precedential); Patent No. 6,849,360

Key point(s):

  • A reference can be used for a teaching outside of its specific details based on how a POSITA would look at and use the reference

HBAC Matchmaker Media, Inc. v. Google, Inc., Nos. 2015-1447, 2015-1478, 2015-1479, 2015-1480, 2015-1481, 2015-1521, 2015-1522, 2015-1523, May 31, 2016 (non-precedential); Patent No. 6,002,393

Key point(s):

  • When a claim term is not defined in the specification, the construction of the term should not be narrowed by preferred embodiments if extrinsic evidence provides a broader definition, but the preferred embodiments may limit the scope of the invention.

Ruckus Wireless, Inc. v. Innovative Wireless Solutions, LLC., Nos. 2015-1425, 2015-1438, May 31, 2016 (Precedential) (2-1); Patent Nos. 5,912,895; 6,327,264; and 6,587,473

Key point(s):

  • Failure of a party or the district court to consult extrinsic evidence during claim construction can be used to limit the claim to the preferred embodiments in appropriate circumstances

Superior Indus., Inc. v. Masaba, Inc., No. 2015-1594, June 2, 2016 (non-precedential); Patent Nos. 7,424,943; 7,470,101; 7,607,529; 7,618,231; and 7,845,482

Key point(s):

  • A claim term that is defined in the specification as always having a specific function or design will be construed in light of that function or design

Medtronic Sofamor Danek USA, Inc. v. NuVasive, Inc., Nos. 2013-1576, 2013-1577, June 3, 2016 (Precedential) (3-0); Patent No. 7,470,236

Key point(s):

  • Substantial evidence that an infringement position is objectively unreasonable is sufficient to show that a jury could, based on this evidence, reasonably have concluded that the defendant had knowledge it was infringing

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