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“Connector Assembly” Does Not Invoke Means-Plus-Function Claim Construction

September 03, 2004

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Last Month at the Federal Circuit - October 2004

Judges: Bryson (author), Plager, and Linn

In Lighting World, Inc. v. Birchwood Lighting, Inc., No. 03-1534 (Fed. Cir. Sept. 3, 2004), the Federal Circuit corrected the district court’s claim construction and vacated a corresponding ruling of SJ of no literal infringement.

Lighting World, Inc. (“Lighting World”) owns U.S. Patent Nos. 5,448,460 (“the ‘460 patent”) and 5,221,139 (“the ‘139 patent”), both of which are directed to commercial lighting fixtures. The claims at issue in the ‘460 patent include the phrase “a connector assembly for connecting each pair of adjacent support members, said connector assembly being pivotally connected to said pair of adjacent support members.” The district court construed this language as a means-plus-function limitation. For the claim of the ‘139 patent, the claim-construction issue centered on the limitation “a plurality of lamp supports mounted on the upper surface of said support member for engaging and supporting said fluorescent lamps adjacent their non-socket ends.” The district court construed this limitation to require that the lamps be supported from below, i.e., against the force of gravity. Based on the claim constructions, the district court ruled that Birchwood Lighting, Inc.’s (“Birchwood”) lighting fixtures did not literally infringe either patent. After Lighting World’s case-inchief, the district court granted Birchwood’s motion for JMOL of no infringement under the DOE.

Concerning the DOE, the Federal Circuit ruled that Lighting World had failed to present evidence regarding equivalents from the perspective of one of ordinary skill in the art and, therefore, sustained the district court’s entry of JMOL of no infringement under the DOE for both patents.

The Federal Circuit ruled that the district court committed claim-construction errors for both patents and, therefore, vacated the judgments of no literal infringement and remanded for further proceedings. With respect to the ‘460 patent, the Federal Circuit disagreed that the claims recited means-plusfunction language. The claims did not include the term “means,” and the phrase “connector assembly” invoked sufficient structure to keep it from the scope of § 112, ¶ 6. The intrinsic record and dictionaries reflected that the terms “connector” and “connector assembly” are used as the names for structure, according to the Court.

Concerning the ‘139 patent, the Federal Circuit found no support in the claim language or the intrinsic evidence for restricting the claim language as the district court had done. According to the Court, the terms “supporting” and “engaging” include more than support or engagement from below, and the fact that the patentee had not included figures depicting support and engagement from other orientations was not sufficient to limit the claim language to only the particular orientations depicted in the figures.