Digest of In re Dwight C. Shaneour, No. 2014-1518 (Fed. Cir. Jan. 8, 2015) (non-precedential). On appeal from United States Patent and Trademark Office (“PTO”), Patent Trial and Appeal Board (“PTAB”). Before Prost, O’Malley, and Taranto. Per Curiam.
Procedural Posture: Applicant appealed the PTAB’s affirmation of the rejection of all claims of patent application entitled “Remote Controlled Athletic Field Lighting System” as obvious over U.S. Patent No. 7,635,958 (Miki) in light of U.S. Patent No. 6,960,892 (Loughrey). CAFC affirmed.
- Prior Art: The CAFC affirmed the PTAB’s determination that the Miki reference was prior art in the “field of endeavor” relevant to Applicant’s invention. The CAFC rejected Applicant’s argument that the preamble dictated the field of endeavor to be “athletic fields’ lighting control systems.” The preamble is not limiting where it merely states the purpose or intended use of the invention. Instead, the CAFC determined that the PTAB did not err in classifying the invention as within the field of “lighting control systems.” Further, even if the field of endeavor was limited as proposed by the Applicant, the Miki reference would still encompass the same because Miki expressly states that the invention applies outdoors.
- Claim Construction: The CAFC also affirmed the PTAB’s construction of the proposed claim terms. In doing so, the CAFC rejected Applicant’s proposed construction that each light sensor is required to be placed at the point of the light’s origin because it was inconsistent with the broadest reasonable construction in light of the specification. The claim language describes each sensor as being “associated with an individual fixture” and “capable of producing a signal related to the light level being produced.” Both phrases are reasonably read as covering sensors slightly removed from the light source. Further, there was no disclosure in the specification or prosecution history justifying a narrower interpretation.
- Obviousness: Based on the prior art and claim construction findings, the CAFC concluded that the PTAB did not err in concluding that Applicant’s claims were obvious based on the Miki and Loughrey references.