Chamberlain Grp. v. Techtronic Indus. Co.
United States Court of Appeals for the Federal Circuit
August 21, 2019, Decided
[*1344] Chen, Circuit Judge.
Techtronic Industries Co. Ltd., Techtronic Industries North America, Inc., One World Technologies, Inc., OWT Industries, Inc., and Ryobi Technologies, Inc. (collectively, TTI) appeal from the opinion and order of the United States District Court for the Northern District of Illinois denying [**2] TTI's motion for judgment as a matter of law (JMOL) and granting Chamberlain Group, Inc.'s (CGI) motions for enhanced damages and attorney fees. TTI also appeals the jury's verdict with respect to infringement and validity. We have jurisdiction under 28 U.S.C. § 1295(a)(1).
Because we conclude that claims 1, 5, and 15 of CGI's U.S. Patent No. 7,224,275 ('275 patent) are directed to an abstract idea and therefore patent-ineligible, we reverse the district court's JMOL decision [*1345] with respect to the '275 patent on 35 U.S.C. § 101 grounds. We affirm the jury's verdict with respect to its finding of no anticipation of claims 14, 17, and 18 of CGI's U.S. Patent No. 7,635,966 ('966 ) by U.S. Patent No. 6,484,784 (Weik). Accordingly, we vacate the district court's injunction and its awards of enhanced damages and attorney fees, and remand to the district court for reconsideration of enhanced damages and attorney fees with respect to only the '966 patent.
A. The '275 Patent
The '275 patent relates to an apparatus and method for communicating information about the status of a movable barrier, for example, a garage door. The '275 patent explains that, "[o]ver time, the capabilities of and features supported by . . . movable barrier operators . . . expanded to include actions other than merely opening and closing a corresponding movable barrier." '275 patent at col. 1, ll. 31-34. Some movable [**3] barrier operators could provide ambient lighting, for example, or sense the presence of an obstacle in the path of the movable barrier and take an appropriate action. Id. at col. 1, ll. 34-38. The '275 patent explains that the movable barrier operator may communicate information relating to the movable barrier's status with respect to these actions with various peripheral devices, including sensors, alarms, displays, lights, and so forth. Id. at col. 1, ll. 54-61. Rather than communicating this information over a physical signaling path, the asserted claims recite communicating it wirelessly. Id. at col. 1, l. 64 - col. 2, l. 16. The specification describes wireless transmitters as being "well understood in the art." Id. at col. 3, l. 54 - col. 4, l. 4.
The parties do not contest the district court's treatment of claim 1 as representative. Claim 1 recites:Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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935 F.3d 1341 *; 2019 U.S. App. LEXIS 24879 **; 2019 U.S.P.Q.2D (BNA) 311576; 2019 WL 3938278
THE CHAMBERLAIN GROUP, INC., Plaintiff-Appellee, v. TECHTRONIC INDUSTRIES CO., TECHTRONIC INDUSTRIES NORTH AMERICA, INC., ONE WORLD TECHNOLOGIES, INC., OWT INDUSTRIES, INC., RYOBI TECHNOLOGIES, INC., Defendants-Appellants, ET TECHNOLOGY (WUXI) CO., Defendant
Subsequent History: Petition for certiorari filed at, 05/15/2020
Prior History: [**1] Appeals from the United States District Court for the Northern District of Illinois in No. 1:16-cv-06097, Senior Judge Harry D. Leinenweber.
Chamberlain Grp., Inc. v. Techtronic Indus. Co., 315 F. Supp. 3d 977, 2018 U.S. Dist. LEXIS 86386 (N.D. Ill., May 23, 2018)
barrier, wireless, movable, patent, wirelessly, inventive, recited, anticipation, transmitter, technology, venue, conventional, enhanced, battery, embodiments, interface, quotation, garage, signal, door, patent-eligible
Patent Law, Jurisdiction & Review, Standards of Review, De Novo Review, Subject Matter, Anticipation & Novelty, Description in Prior Patents, Combinations, Fact & Law Issues, Substantial Evidence, Civil Procedure, Appeals, Abuse of Discretion, Evidence, Admissibility, Reversible Errors, Preliminary Considerations, Venue, Motions to Transfer, Federal Venue Transfers, Improper Venue Transfers, Business & Corporate Compliance, Infringement Actions, Patent Law, Infringement Actions, Trials, Jury Trials, Jury Instructions