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In some cases, the ordinary meaning of patent claim language as understood by a person of skill in the art may be readily apparent even to lay judges, and claim construction in such cases involves little more than the application of the widely accepted meaning of commonly understood words. In such circumstances, general purpose dictionaries may be helpful. In many cases that give rise to litigation, however, determining the ordinary and customary meaning of the claim requires examination of terms that have a particular meaning in a field of art. Because the meaning of a claim term as understood by persons of skill in the art is often not immediately apparent, and because patentees frequently use terms idiosyncratically, the court looks to those sources available to the public that show what a person of skill in the art would have understood disputed claim language to mean. Those sources include the words of the claims themselves, the remainder of the specification, the prosecution history, and extrinsic evidence concerning relevant scientific principles, the meaning of technical terms, and the state of the art.
Edward H. Phillips invented modular, steel-shell panels that could be welded together to form vandalism-resistant walls. The panels were especially useful in building prisons because they were load-bearing and impact-resistant, while also insulating against fire and noise. Mr. Phillips obtained a patent on the invention, U.S. Patent No. 4,677,798 ("the '798 patent"), and he subsequently entered into an arrangement with AWH Corporation, Hopeman Brothers, Inc., and Lofton Corporation (collectively "AWH") to market and sell the panels. The arrangement ended in 1990. In 1991, however, Mr. Phillips received a sales brochure from AWH that suggested to him that AWH was continuing to use his trade secrets and patented technology without his consent. In a series of letters in 1991 and 1992, Mr. Phillips accused AWH of patent infringement and trade secret misappropriation. Correspondence between the parties regarding the matter ceased after that time. In February 1997, Mr. Phillips brought suit in the United States District Court charging AWH with misappropriation of trade secrets and infringement of the '798 patent. The district court dismissed the trade secret misappropriation claim as barred by Colorado's three-year statute of limitations. With regard to the patent infringement issue, the district court focused on the language of claim 1, which recited "further means disposed inside the shell for increasing its load bearing capacity comprising internal steel baffles extending inwardly from the steel shell walls." Upon examination, the district court concluded that for purposes of the '798 patent, a baffle must "extend inward from the steel shell walls at an oblique or acute angle to the wall face" and must form part of an interlocking barrier in the interior of the wall module. Because Phillips could not prove infringement under that claim construction, the district court granted summary judgment of non-infringement. Phillips thereafter appealed.
Did the district court err in: (i) dismissing the trade secret misappropriation claim as barred by Colorado's three-year statute of limitations; and in (ii) holding that Phillips could not prove infringement under the claim construction incorporated in claim 1?
(i) No; (ii) Yes.
The U.S. Circuit Court of Appeals held that the district court was correct in dismissing the trade secret misappropriation claim as the same was barred by Colorado's three-year statute of limitations. However, the Court held that the district court erred in basing its decision to grant summary judgment of non-infringement on the language of claim 1. According to the Court, the district court erred by limiting the term “baffles” to corresponding structures disclosed in the specification and their equivalents. The Court ruled that the fact that the written description of the patent set forth multiple objectives to be served by the baffles in the claims confirmed that the term should not have been read restrictively to require that the baffles serve all of the recited functions. The Court held that a person of ordinary skill in the art would not have interpreted the disclosure and claims to mean that a structure extending inward from one of the wall faces was a "baffle" if disposed at an acute or obtuse angle, but was not a "baffle" if disposed at a right angle.