Markman v. Westview Instruments

517 U.S. 370, 116 S. Ct. 1384 (1996)

 

RULE:

The construction of a patent, including terms of art within its claim, is exclusively within the province of the court.

FACTS:

Petitioner, the owner of a patent that described a system that could monitor and report the status, location, and movement of clothing in a dry-cleaning establishment, filed a suit against respondents, the maker of an alleged infringing product (maker) and an operator of a dry-cleaning establishment using the alleged infringing product, for patent infringement. Respondent maker denied infringement. Part of the dispute hinged upon the meaning of the word "inventory," a term found in one of petitioner's claims. A jury found infringement. However, the trial court granted respondents' deferred motion for judgment as a matter of law, because under its interpretation of "inventory," respondent maker's system did not infringe petitioner's patent. That judgment was affirmed by the Supreme Court.

ISSUE:

Is the construction of a patent, including terms of art within its claim, exclusively within the province of the court?

ANSWER:

Yes.

CONCLUSION:

 The judgment of the court below was affirmed on appeal based on the Court's holding that the construction of a patent, including terms of art within its claim, were exclusively within the province of the courts. Therefore, the interpretation of the word "inventory" in the case at hand was an issue for the judge, not the jury.

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