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Nothing Precludes a District Court from Making Adjustments to a Claim Construction as a Trial Proceeds

August 17, 2004

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Last Month at the Federal Circuit - September 2004

Judges: Gajarsa (author), Michel, and Prost

In Power Mosfet Technologies, L.L.C. v. Siemens AG, No. 03-1083 (Fed. Cir. Aug. 17, 2004), the Federal Circuit affirmed a finding of noninfringement. Power Mosfet Technologies, L.L.C. (“PMT”) owns U.S. Patent No. 5,216,275 (“the ‘275 patent”), which is directed to a specific type of MOSFET semiconductor power device. PMT sued Infineon Technologies Corporation and related companies (collectively “Infineon”), STMicroelectronics, N.V. and related companies (collectively “ST”), and International Rectifier Corporation and related companies (collectively “IR”).

An SM construed the claims, and the district court found no infringement. The district court also found that the ‘275 patent was not invalid.

The Federal Circuit engaged in a detailed analysis of specific claim limitations, only to conclude that the record revealed both an incomplete claim construction containing a significant ambiguity and an awareness by the parties that the limited constructions that did exist were subject to further modification by the district court. In the end, the Federal Circuit affirmed the district court’s claim constructions and its judgment of noninfringement.

The Federal Circuit also denied Infineon’s request for attorney fees, because, according to the district court, all of the parties had conducted themselves without the decorum required when practicing before a federal court. The Federal Circuit characterized Infineon’s request for attorney fees in view of the district court’s admonition as “quite bold.”