Advanced Fiber Technologies (AFT) Trust v. J & L Fiber Services, Inc.
674 F.3d 1365
| Fed. Cir. | 2012Background
- This case involves Advanced Fiber Technologies (AFT) Trust patent RE39,940 on screen cylinders for pulp and paper screening; platter of claims include screening medium, backing plate, and openings/slots.
- District court construed terms: screening medium and perforated; openings/slots restricted; per the prosecution history, AFT distinguished Gillespie to limit scope.
- The district court held the accused J&L V-Max wedgewire screen did not literally infringe under the construed terms, but found no doctrine of equivalents due to disclosure-dedication; summary judgment of noninfringement granted.
- The court denied summary judgment of invalidity with respect to PIMA; validity dispute focuses on whether PIMA would render obvious the claimed invention.
- The district court granted summary judgment of no willful infringement, finding reasonable defenses and post-filing claim term changes during reissue prosecution.
- AFT appeals, challenging claim constructions and the denial of invalidity summary judgment, asking reversal on noninfringement and remand; the court affirms willfulness finding and reverses noninfringement on remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Construction of screening medium and perforated | AFT argues perforated means holes; wedgewire disclosed. | J&L argues district court correctly limited perforated to pierced holes. | Perforated means having holes; wedgewire encompassed by other evidence; district error reversed. |
| Construction of slots and openings | Claims not limited to small sizes; Gillespie disclosure creates no disclaimer. | AFT distinguished Gillespie to limit size; disclaimer supports narrow scope. | Slots/openings limited to widths less than 0.254 mm based on disclaimer; upheld on remand. |
| Obviousness over PIMA | PIMA cannot anticipate the '940 claims. | PIMA could render obvious given the field. | Not addressed on appeal as to validity; remand possible; decision not necessary for willfulness. |
| Willful infringement | J&L acted willfully despite doubt about validity/infringement. | Reasonable defenses and post-filing prosecution history show objective reasonableness. | Willful infringement affirmed; district court’s reasoning upheld. |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (intrinsic evidence governs claim construction; prosecution history informs meaning)
- Markman v. Westview Instruments, Inc., 52 F.3d 967 (Fed. Cir. 1995) (claims construed by court; patent as integrated instrument)
- Cybor Corp. v. FAS Techs., Inc., 138 F.3d 1448 (Fed.Cir. 1998) (claim construction is a legal question on appeal)
- Edwards Lifesciences LLC v. Cook Inc., 582 F.3d 1322 (Fed. Cir. 2009) (derivative construction of non-claim term when necessary to illuminate meaning)
- In re Seagate Tech., LLC, 497 F.3d 1360 (Fed.Cir. 2007) (objective standard for willful infringement; requires clear and convincing evidence)