In GE LIGHTING SOLUTIONS, LLC v. AGILIGHT, INC., Appeal No. 13-1267, the Federal Circuit reversed in part and affirmed in part summary judgments of non-infringement based on claim construction.
GE sued AgiLight for infringing patents relating to LEDs. The claims included the terms “IDC connector,” “optical element having a substantially ellipsoidal inner profile and generally spherical outer profile,” and “annular gasket.” After claim construction, the parties stipulated to non-infringement of some of the patents based on the district court’s claim construction, and the district court granted a motion for summary judgment of non-infringement of the other patents. GE appealed.
The Federal Circuit reversed the district court’s construction of “IDC connector” because it improperly imported structural limitations from the preferred embodiment and dependent claims. There was no dispute that the term IDC connector was a commonly used term with a plain meaning. Even though the specification disclosed only one embodiment, it is improper to read limitations from a preferred embodiment into the claims absent a clear indication in the intrinsic record that the patentee intended the claims to be so limited, e.g., via lexicography or disavowal. Because no such circumstances were present in this case, the Federal Circuit reversed.
The Federal Circuit also reversed the district court on whether there was a genuine factual dispute concerning infringement due to the parties’ differing interpretations of the terms “substantially ellipsoidal inner profile” and “generally spherical outer profile.” Both parties stipulated to definitions of the terms; nevertheless, a dispute arose over whether the entire inner profile must be substantially ellipsoidal or whether the claims can be met if a portion of the inner profile is substantially ellipsoidal. The Federal Circuit adopted the latter interpretation because the former would exclude the specification’s only disclosed embodiment. For similar reasons, the Federal Circuit also reversed the district court’s interpretation of the term “generally spherical outer profile.”