GE Lighting Solutions, LLC v. AgiLight, Inc., No. 2013-1267 (May 1, 2014) precedential (3-0), Patent Nos. 7,160,140, 7,520,771, 7,832,896 and 7,633,055

Key points:

• Deviation from the plain meaning of a term in a claim may be compelled when the patentee acts as its own lexicographer or the patentee disavows the plain meaning.
• A court should not construe claims in a manner that would exclude the preferred embodiment unless there is probative evidence to the contrary.