Case: Bose Corp. v. SDI Technologies, Inc., No. 2013-1347 (Fed. Cir. Mar. 14, 2014) (non-precedential). On appeal from D. Mass. Before Chen, Clevenger, and Hughes.
Procedural Posture: Plaintiff appealed the summary judgment of noninfringement. CAFC affirmed in part, reversed in part, and remanded.
- Claim Construction: The district court correctly concluded that “interface” is “circuitry that converts a digital audio signal from an audio source to an analog audio signal and transmits digital control commands,” as opposed to merely a “connection”, given (1) plaintiff surrendered an embodiment to the public by virtue of its claim amendments that replaced “connection” with “interface” and (2) the specification clearly distinguished the two terms. The district court also correctly concluded that the terms “interface unit,” “interface device,” and “interface module” refer to structures that are “singularly physical, not defined on paper as different pieces of separate devices,” in light of the parties’ agreement that the three terms each be construed as “a structure that includes an interface,” and the specification’s distinction between each of the aforementioned and devices physically separated from them.
- Indirect Infringement: The district court improperly relied on the fact that defendant obtained an opinion of counsel in determining it did not have the requisite mental state for inducement. When the record reveals no basis for a good-faith belief sufficient to thwart liability, summary judgment of no liability cannot stand. Defendant did not show it relied in good-faith on its opinion of counsel, or that it exercised reasonable good-faith adherence to the analysis in the opinion and the advice therein. The USPTO’s rejection of the patent claims during reexamination, using the same references as identified in defendant’s opinion of counsel, does not prove defendant’s good-faith reliance. Further, whether defendant had a good-faith belief, e.g., of invalidity, between the time it learned of the patent and the time it obtained an opinion of counsel, is a triable issue for the jury to consider.