Summary: CAFC affirmed decision sanctioning plaintiff for bringing frivolous lawsuit.

Case: Source Vagabond Sys. Ltd. v. Hydrapak, Inc., Nos. 2013-1270, -1387 (Fed. Cir. June 5, 2014) (precedential). On appeal from S.D.N.Y. Before Moore, Reyna and Wallach.

Procedural Posture: Plaintiff appealed district court decision imposing Rule 11 sanctions for bringing frivolous patent infringement suit. CAFC affirmed.

  • Sanctions: The CAFC found that the district court did not abuse its discretion in imposing sanctions because appellant made frivolous claim construction arguments, its literal infringement claim lacked evidentiary support no matter how the claim was construed, and it failed to provide a showing of exactly why, prior to filing suit, it believed its claim of infringement under the doctrine of equivalents was reasonable.
  • Claim Construction: The CAFC found the appellant’s proposed claim constructions to be unreasonable because appellant added language to the otherwise unambiguous claim language without support from the prosecution history or specifications. The CAFC further rejected appellant’s attempts to support its proposed construction with drawings from the patent, the purpose of the invention, and the possibility of a nonsensical result because none of these justified adding language to the plain meaning of the claim.

Aryn Conrad