In Core Wireless Licensing S.a.r.l. v. Apple Inc., Appeal No. 2015-2037, the Federal Circuit affirmed a claim construction supported by the claim language and specification.
Core Wireless sued Apple for patent infringement and a jury found no infringement. Core Wireless moved for JMOL regarding a single claim directed to a means for a mobile station to select the channel for uploading packet data to a network. Core Wireless argued that the court’s construction of the “means for comparing” limitation did not require that the mobile station be capable of making uplink channel decisions. The district court disagreed, and held “means for comparing” does require that the mobile station be capable of performing “channel selection.”
The Federal Circuit affirmed the district court’s construction. The Court noted that the entire point of the claimed invention was to enable the mobile station to make the channel selection decision. The Court found that the specification of the patent, including the Abstract, Summary of the Invention, and each embodiment, describes a structure in which the channel selection decision is made at the mobile station. The Court also found the function of the “means for comparing” limitation is to compare the values for the purpose of channel selection, thus the corresponding structure must be capable of channel selection.