Federal Circuit Vacates Summary Judgment of Non-Infringement Based on Claim Construction That Erroneously Imported Embodiments into the Claim

In IQRIS Technologies LLC v. Point Blank Enterprises, Inc, No. 2023-2062 (Fed. Cir. Mar. 7, 2025), the Federal Circuit vacated the district court’s grant of summary judgment of noninfringement of U.S. Patent Nos. 7,814,567 and 8,256,020, holding that the district court erroneously construed the term “pull cord.”

IQRIS’s patent claims are directed to a quick-release system for tactical vests. The claims recite “pull cord” which the wearer uses to initiate release, but the accused infringing products rely on a trigger mechanism. “Pull cord” was construed to (1) require a user pull on the cord directly and (2) exclude cords with handles. Under this construction, the district court held that no reasonable jury could find the accused products infringe IQRIS’s patents either literally or under the doctrine of equivalents. IQRIS appealed.

The Federal Circuit rejected the district court’s construction. The intrinsic record did not support narrowly construing “pull cord” to require direct pulling or to exclude a handle. Although the specification criticized prior art cutaway vests with a handle, it did not disparage the handle per se. So those criticisms did not meet the “exacting” standard requiring clear and unequivocal evidence of disavowal. The Federal Circuit vacated and remanded in light of the new construction.