Summary Judgment of Noninfringement Affirmed in Cruise Control System Patent Suits Against BMW

The U.S. Court of Appeals for the Federal Circuit affirmed summary judgment decisions of non-infringement in Carrum Technologies, LLC’s patent infringement suits against Finnegan client BMW.

The court held that the district court was not wrong in its claim constructions, which formed the basis for the non-infringement findings. The patents at issue, U.S. Patent Nos. 7,512,475 and 7,925,416, relate to adaptive cruise control performance in curved driving conditions.

Carrum challenged the district court’s construction of the term “a controller,” arguing that the functions listed in the claims could be distributed among multiple controllers. The Federal Circuit disagreed. They found that the claim language required at least one controller to perform all listed functions. Carrum also disputed the construction of the term “change in... vehicle lateral acceleration,” asserting that a comparison to a predetermined threshold should qualify. The court found that the specification, claim language, and prosecution history supported the requirement for two actual measurements of lateral acceleration.

The Federal Circuit upheld the district court’s claim constructions and the resulting summary judgments of non-infringement.

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