American Piledriving Equipment, Inc. v. Geoquip, Inc.
637 F.3d 1324
| Fed. Cir. | 2011Background
- Consolidated appeals involve the '964 patent for vibratory pile drivers, addressing claim constructions and infringement across seven district suits.
- Disputed terms include eccentric weight portion, integral, and insert-receiving area, with Virginia and California courts adopting different constructions.
- Virginia court granted summary judgment of noninfringement; California court also granted noninfringement despite different term constructions.
- District courts denied infringement as to the accused Model 250/500 devices; Virginia action largely dismissed invalidity as moot, California action dismissed based on other grounds.
- The Federal Circuit affirms Virginia’s constructions, and partly reverses California’s constructions, remanding for further proceedings consistent with its opinion.
- The '964 patent discloses counterweights with an eccentric weight portion extending from the gear, with inserts and materials intended to address prior-art deficiencies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of eccentric weight portion | American argues functionally broad | Geoquip/Bay Machinery argue distinct parts | Virginia construction adopted; California overbroad |
| Meaning of integral | Integral should be broader than one-piece | Integral means one-piece | Integrated = formed or cast of one piece |
| Insert-receiving area | Bore could be within eccentric weight portion | Bore extends fully through gear and eccentric weight | Virginia: bore at least partially within eccentric weight portion; California reversed to similar scope |
| Infringement of claims 1/6/11/16; Early Model 500 | Models infringe under certain constructions | No infringement under adopted constructions | Model 250/500 noninfringement; Early Model 500 infringes 16–18; remand for California action |
| Remand and final disposition | Need clarification on scope | No further action needed | Affirm Virginia; partially reverse California; remand |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claim terms interpreted with intrinsic evidence; ordinary meaning)
- Cybor Corp. v. FAS Techs., 138 F.3d 1448 (Fed. Cir. 1998) (claim construction de novo review)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir. 1996) (reliability of sources for claim construction; intrinsic evidence primary)
- Innova/Pure Water, Inc. v. Safari Water Filtration Sys., Inc., 381 F.3d 1111 (Fed. Cir. 2004) (extrinsic evidence and claim interpretation guidance)
- Seachange Int'l, Inc. v. C-COR Inc., 413 F.3d 1361 (Fed. Cir. 2005) (prosecution history can limit claim scope)
- Andersen Corp. v. Fiber Composites, LLC, 474 F.3d 1361 (Fed. Cir. 2007) (disclaimer during prosecution can limit claim scope)
- Microsoft Corp. v. Multi-Tech Sys., Inc., 357 F.3d 1340 (Fed. Cir. 2004) (prosecution statements relevant to claim interpretation)