Wells-Gardner Elecs. Corp. v. C. Ceronix, Inc., No. 10 C 2536, Slip Op. (N.D. Ill. Apr. 14, 2011) (Hart, J.).
Judge Hart construed the term "flange" and granted defendant C. Ceronix summary judgment of noninfringement in this patent case involving flat panel television mounting frames. The Court held that "flange" as used in the claims was interchangeable with "bracket," which C. Ceronix argued should be excluded from the definition of flange. In addition to the intrinsic evidence, the Court looked to dictionary definitions of flange.
C. Ceronix had brackets on the sides of the frame, but the brackets did not directly attach to the sides of the flat panel display as required by the claim. Instead the bracket attached at the back of the display. The doctrine of equivalents did not apply because allowing a flange that attached at the back not the side would vitiate the claim element.
The Court exercised its discretion to dismiss C. Ceronix's claim for declaratory judgment of invalidity.