Markman v. Westview Instruments, Inc. - 52 F.3d 967 (Fed. Cir. 1995)

Rule:

In a case tried to a jury, the court has the power and obligation to construe as a matter of law the meaning of language used in the patent claim. As such, a patent covers the invention or inventions which the court, in construing its provisions, decides that it describes and claims. Because claim construction is a matter of law, the construction given the claims is reviewed de novo on appeal.

Facts:

Plaintiffs, both inventor/owner of patent for inventory control system for dry cleaning stores and his licensee, sued defendants for patent infringement. Jury returned a verdict that defendants infringed on two of plaintiffs' claims. District court granted defendants' deferred motion for judgment as a matter of law (JOML), stating claim construction was a matter of law for the court, and that "inventory" as used in claims meant "articles of clothing" and not transaction totals or dollars. According to the district court, the defendants' device did not have the means to maintain an inventory total, and thus did not infringe on plaintiffs' patent. Plaintiffs appealed. 

Issue:

Did the district court err in granting defendants’ motion for judgment as a matter of law? 

Answer:

No.

Conclusion:

The appellate court agreed with district court and affirmed, holding that the district court properly concluded that claim construction was a matter of law for the trial court and it did not err in granting defendants' motion for judgment as a matter of law or in admitting extrinsic evidence on the claim construction issue only.