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Camatic Proprietary Ltd. v. Irwin Seating Co.

United States District Court, W.D. Michigan, Southern Division

December 27, 2017

CAMATIC PROPRIETARY LIMITED and CAMATIC SEATING, INC., Plaintiffs,
v.
IRWIN SEATING COMPANY, Defendant. Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin Camatic Irwin

          CLAIM CONSTRUCTION MEMORANDUM OPINION AND ORDER

          ROBERT J. JONKER CHIEF UNITED STATES DISTRICT JUDGE

         INTRODUCTION

         This is a patent infringement case. Camatic Proprietary Limited and Camatic Seating, Inc. (collectively, “Camatic”) allege that Irwin Seating Company (“Irwin”) is infringing Camatic's U.S. Patent No. 7, 073, 858 (“the ‘858 Patent”). Irwin denies infringement and asserts that the ‘858 Patent is invalid. Both companies work in the seating field. (ECF No. 39, PageID.1108-1109.) The patent at issue in this case relates to seating systems used in sports stadiums, among other uses. (Id.) Camatic submits one term of the ‘858 Patent for construction, and argues that plain and ordinary meaning is enough for everything else. Irwin submits fourteen terms for construction. (ECF No. 58-1.) The terms Irwin identifies for construction fall within three categories: (1) terms Irwin asserts invoke means-plus function under 35 U.S.C. § 112; (2) terms Irwin asserts call for construction beyond the plain and ordinary meaning; and (3) phrases Irwin alleges are indefinite. (Id.) The Court has heard oral argument on the parties proposed claims constructions. (ECF No. 94.) This Claims Construction Memorandum contains the Court's construction of the disputed terms.

         CLAIM CONSTRUCTION PRINCIPLES

         When the meaning of a claim's language is disputed, the court must construe the claim as a matter of law. Markman v. Westview Instruments, Inc., 52 F.3d 967, 979 (Fed. Cir. 1995) (en banc), aff'd 517 U.S. 370, 116 S.Ct. 1384 (1996). Proper claim construction begins with the language of the claims themselves. See Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1582 (Fed. Cir. 1996). “‘In construing claims, the analytical focus must begin and remain centered on the language of the claims themselves, for it is that language that the patentee chose to use to particularly point[] out and distinctly claim[] the subject matter which the patentee regards as his invention. 35 U.S.C. § 112, ¶ 2.'” Brookhill-Wilk 1, LLC v. Intuitive Surgical, Inc., 334 F.3d 1294, 1298 (Fed. Cir. 2003) (quoting Interactive Gift Express, Inc. v. Compuserve, Inc., 256 F.3d 1323, 1331 (Fed. Cir. 2001) (internal quotations omitted)). The Court must give claim terms the ordinary and customary meaning ascribed to them by “a person of ordinary skill in the art in question at the time of the invention, i.e, as of the effective filing date of the patent application.” Phillips v. AWH Corp., 415 F.3d 1303, 1313 (Fed. Cir. 2005) (en banc).

         When interpreting a claim as understood by a person of ordinary skill in the art, the court first examines the intrinsic evidence before it, which includes not only the claim language, but also the written description and the prosecution history of the patent. Phillips, 415 F.3d at 1319. Terms that have a plain and ordinary meaning typically do not need to be construed, as their meaning is clear from the term itself. See Finjan, Inc. v. Secure Computing Corp., 626 F.3d 1197, 1207 (Fed. Cir. 2010). A court considers the written description “because it is relevant not only to aid in the claim construction analysis, but also to determine if the presumption of ordinary and customary meaning is rebutted.” Brookhill-Wilk 1, LLC, 334 F.3d at 1298. In fact, the specification is usually “the single best guide to the meaning of a disputed term.” Vitronics, 90 F.3d at 1582. The prosecution history may also be considered to “inform the meaning of the claim language by demonstrating how the inventor understood the invention and whether the inventor limited the invention in the course of prosecution, making the claim scope narrower than it would otherwise be.” Phillips, 415 F.3d at 1317.

         A court may also consider extrinsic evidence, such as dictionaries, treatises, and expert or inventor testimony, in construing patent claims. See Id. Technical dictionaries may help a court understand “the meaning of particular terminology to those of skill in the art of the invention.” Id. at 1318. Likewise, expert testimony may be useful for explaining the technology at issue and how the particular invention works, to ensure that the court's understanding of the technical aspects of the patent is consistent with that of a person of ordinary skill in the art, or to establish that a particular claim in the patent or in prior art has a particular meaning in the pertinent field. See id.

         While a court may consider both intrinsic and extrinsic evidence, intrinsic evidence is generally more reliable and thus generally entitled to greater weight when construing a claim term. See Id. at 1320-21. What ultimately controls, however, is the language of the claims themselves: “[T]he court's focus [must] remain[] on understanding how a person of ordinary skill in the art would understand the claim terms.” Id. at 1323. Thus, “‘[t]he construction that stays true to the claim language and most naturally aligns with the patent's description of the invention will be, in the end, the correct construction.'” Id. at 1316 (quoting Renishaw PLC v. Marposs Societa' per Azioni, 158 F.3d 1243, 1250 (Fed. Cir. 1995)).

         CLAIM ANALYSIS

         1.Means-Plus-Function

         The Patent Act provides that “[a]n element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.” 35 U.S.C. § 112(f) (2017). This provision strikes “a balance in allowing patentees to express a claim limitation by reciting a function to be performed rather than by reciting structure for performing that function, while placing specific constraints on how such a limitation is to be construed, namely, by restricting the scope of coverage to only the structure, materials, or acts described in the specification as corresponding to the claimed function and equivalents thereof.” Williamson v. Citrix Online, LLC, 792 F.3d. 1339, 1347 (Fed. Cir. 2015). In determining whether a particular limitation is a means-plus-function term, “the essential inquiry is not merely the presence or absence of the word ‘means' but whether the words of the claim are understood by persons of ordinary skill in the art to have a sufficiently definite meaning as the name for structure.” Id. at 1348. The presence or absence of the word “means” still affects the analysis: when the claim uses the word “means, ” there is a rebuttable presumption that § 112(f) applies. Id. Conversely, when the word “means” does not appear, there is a rebuttable presumption that § 112(f) does not apply. Id. “When a claim lacks the word ‘means, ' the presumption can be overcome and § 112[f] will apply if the challenger demonstrates that the claim term fails to recite sufficiently definite structure or else recites function without reciting sufficient structure for performing that function.” Id. (internal quotation omitted).

         Irwin identifies four claim terms as subject to a means-plus-function construction under 35 U.S.C. § 112(f). Camatic contends that section 112(f) does not apply to any of these terms. The Court addresses the claim terms at issue in turn.

858 Claim Term (Asserted Claims)
Camatic
Irwin

connector”

(claims 13, 20, 22, 33, 36)

35 U.S.C. § 112 (f) does not apply, and no construction is necessary. This term should be interpreted according to its plain and ordinary meaning as “something that connects.”

35 U.S.C. § 112(f) applies.

Function: connecting a bracket, a beam, and a bolt.

Structure: an object, like connector 30, that (i) is shaped to be inserted into a channel, (ii) includes an upwardly facing recess to receive the head of a bolt; and (iii) includes an aperture therethrough to receive the shaft of the bolt.

         The Court agrees with Camatic and finds that a means-plus-function analysis under 35 U.S.C. § 112(f) does not apply to the term “connector.” The word “means” does not appear in the claim recitations, and so there is a rebuttable presumption that section 112(f) does not apply. Williams, 792 F.3d at 1347. Irwin has not rebutted the presumption, because it has not demonstrated that the claim term “fails to recite sufficiently definite structure or else recites function without reciting sufficient structure for performing that function.” Id. (internal quotation omitted). A person of ordinary skill in the art would understand the term as used in the ‘858 patent to connote structure.

         The word in context connotes structure by describing connectors in relationship to other structures; the word is not simply describing a function disembodied from structure. Claim 13 recites:

a plurality of connectors, each of the connectors being mountable to a respective one of the brackets; an elongate beam adapted to be mounted to the connectors in a general horizontal orientation, the beam including a lower portion defining a channel, the channel being shaped to slidably receive the connectors from an end of the beam . . . At least one seat support, each seat support including a clamp portion adapted to be ...

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