06/29/2014

GE Lighting Solutions v. Agilight: Construing "IDC connector," "substantially ellipsoidal," and "annular gasket"


Category: Claim Construction  
 
 
 
By: Christian Hannon, Contributor 
 
TitleGE Lighting Solutions, LLC v. Agilight, Inc., No. 2013-1267 (Fed. Cir. May 1, 2014).
IssueGE Lighting Solutions, LLC (GE) appeals from the district court's grant of summary judgment that AgiLight, Inc.'s (AgiLight) accused products and processes do not infringe asserted claims of GE's U.S. Patent Nos. [A] 7,160,140 [the '140 Patent] [and] 7,520,771 [the '771 Patent] [based on a construction of "IDC connector"], [B] 7,832,896 [the '896 Patent] [based on a construction of "substantially ellipsoidal"] and [C] 7,633,055 [the '055 Patent] [based on a construction of "annular gasket"].
GE Lighting Solutions, LLC at *2 (text added).
HoldingWe reverse the grant of summary judgment with regard to the '140, '771 and '896 patents and remand [because [A] the district court's construction of "IDC connector" departed from its plain and ordinary meaning without being necessitated by the intrinsic recor, and [B] the district court's construction of "substantially ellipsoidal" would exclude an actual example embodiment is the specification]. [C] We affirm the grant of summary judgment with regard to the '055 patent [because the district court's construction of "annular gasket" was consistent with its plain and ordinary meaning].
Id. (text added).
 
 
 
 

Procedural HistoryGE sued AgiLight, alleging infringement of various claims of the asserted patents. After claim construction, the parties stipulated to noninfringmenet of the '140 and '771 patents on the grounds that AgiLight's products do not include an "IDC connector" as construed by the court. The district court entered partial summary judgment consistent with the parties' stipulation. The district court also granted AgiLight's motion for summary judgment of noninfringement of the '896 and '055 patents. GE appeals.
GE Lighting Solutions, LLC at *2.
 
 
Legal Reasoning (Rader, Moore and Reyna)
[A] The '140 and '771 Patents
Background & District Court TreatmentThe asserted claims of these two patents recite a string light engine including, among other things, an IDC connector. [...] The district court recognized that an IDC connector is commonly used in electrical engineering to connote a range of devices but found that the '140 and '771 patents were limited to a more specialized IDC connector.
GE Lighting Solutions, LLC at *4-5. (internal quotations omitted) (text deleted).
Federal Circuit's AnalysisWe hold that the district court incorrectly construed [the claimed] IDC connector. Nothing in the intrinsic record requires a departure from [the IDC connector's] plain and ordinary meaning. The specification and prosecution history only compel departure from the plain meaning in two instances: lexicography and disavowal. [...] There is no lexicography or disavowal here. The specifications and their prosecution histories do not define IDC connector or include any indication that the inventors intended to act as their own lexicographers.
Id. at *5-6 (text added) (text deleted).
[B] The '896 Patent
Background & District Court TreatmentThe '896 patent discloses an optical element that houses an LED and interacts with the light emitted therefrom to increase its viewing angle. All of the asserted claims recite a light engine with an "optical element having a substantially ellipsoidal inner profile and generally spherical outer profile." On appeal, GE challenges the disrict court's determination on summary judgment that the accused AgiLight structure lacks a substantially ellipsoidal inner profile. The district court held that "the entirety of the [AgiLight] lens" must be substantially ellipsoidal. The district court found that a portion of the AgiLight lens was "arguably" ellipsoidal, but that the AgiLight lens also included non-ellipsoidal, conical portions. Thus, the court granted summary judgment of noninfringement.
GE Lighting Solutions, LLC at *8-9 (internal citations omitted).
Federal Circuit's Analysis: A Close CaseThis is a close case, [...] were we to adopt AgiLight's proposed construction, that the entire inner profile must be substantially ellipsoidal, we would exclude the specification's only disclosed embodiment [which discloses only a portion of the inner profile is substantially ellipsoidal]. [...] [W]here claims can reasonably [be] interperted to include a specific embodiment, it is incorrect to construe the claims to exclude that embodiment, absent probative evidence on the contrary. No such evidence exists in this case that would require us to construe [the claim term] "substantially ellipsoidal inner profile" in a manner that would exclude [the disclosed embodiment]. [...] We conclude that [the] district court erred when it required the entire inner profile to be substantially ellipsoidal.
Id. at *9-11 (internal citations omitted) (text added).
Federal Circuit's Analysis: Conclusion on the '896 PatentGiven this construction, there is a genuine factual dispute as to whether the accused structure includes a "substantially ellipsoidal inner profile." [...] We thus reverse the district court's grant of summary judgment with regard to the '896 patent and remand.
Id. at *11-12.
[C] The '055 Patent
Background & District Court TreatmentThe '055 patent is directed to an overmoldingprocess that applies a protective sealant over the printed circuit board (PCB) to which an LED is attached, but not over the LED iteself. To ensure that the protective sealant does not cover the LED, an "annular gasket" surrounds the LED before it is placed into an injection mold. [...] The district court construed "annular gasket" to be "a three-dimensional deformable material used to make a pressure-tight joint between stationary parts, with an opening in its center capable of sealing off its center area when bonded statically between stationary parts on its top and bottom." [...] The district court granted summary judgement of non-infrignement based on the "annular gasket" limitation.
GE Lighting Solutions, LLC at *13-15.
Federal Circuit's Analysis & ConclusionWe agree with the district court that AgiLight's domeshaped lens is not an annular gasket because it does not have "an opening." [...] This is consistent with plain and ordinary meaning of a "gasket" and with the annular gaskets disclosed in the '055 patent [...]. There is no genuine issue of material fact. Under the proper claim construction, AgiLight's dome-shaped lens is not an annular gasket becuase it lacks an opening. We affirm the court's grant of summary judgment of the '055 patent on this ground.
Id. at *15-16.
Conclusion
We affirm the grant of summary judgement with regard to the '055 patent. We reverse the grant of summary judgement with regard to the '140, '771 and '896 patents and remand.
GE Lighting Solutions, LLC at *16.
 
 
REYNA, Circuit Judge, concurring-in-part and dissenting-in-part. GE Lighting Solutions, LLC, Reyna Op., at *1.
I agree with the majority's opinion regarding [the '140, '771 and '055 patents]. I disagree, however, with the majority's interpretation of the terms [...] in the '896 patent. I therefore dissent to the majority's outcome concerning the '896 patent.
GE Lighting Solutions, LLC, Reyna Op., at *1-2.
 
 
 
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