Arlington Industries, Inc. v. Bridgeport Fittings, Inc.
632 F.3d 1246
Fed. Cir.2011Background
- Two parallel litigations between Arlington and Bridgeport about the '050 and '831 patents in the MD Pa district court.
- Arlington I held the term 'spring metal adaptor' means adaptor made of spring metal, no split requirement.
- Arlington II adopted a 'split' limitation for both 'spring metal adaptor' and 'spring steel adapter' terms, leading to summary judgment of noninfringement for Bridgesport.
- The Federal Circuit vacated the district court's summary judgments and remanded for further proceedings, agreeing the 'split' import was improper for both terms.
- This court also declined to address the 'circular' and 'outwardly sprung members' constructions on the current record, noting need for more briefing.
- Circuit Judge Lourie concurred in part and dissented in part, urging a different view on the '050 patent specification and claim scope.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 'spring metal adaptor' requires a split | Arlington: no split; adaptor made of spring metal. | Bridgeport: should be read as split due to the term's disclosure and related claims. | Not required; term means adaptor made of spring metal. |
| Whether 'spring steel adapter' requires a split | Arlington: no split; term refers to material and overall adaptor structure. | Bridgeport: should be read as split per patent family and disclosure. | Not required; term means adapter made from spring steel. |
| Whether to address the district court's constructions of 'circular' and 'outwardly sprung members' at this stage | Arlington argues these terms are relevant but not yet properly briefed. | Bridgeport asserts the district court correctly construed them. | Declined to rule on these terms on the record, due to need for more briefing. |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claims define invention; specification guides construction)
- Cybor Corp. v. FAS Techs., Inc., 138 F.3d 1448 (Fed. Cir. 1998) (claim construction de novo review)
- Vitronics Corp. v. Conceptronic, 90 F.3d 1576 (Fed. Cir. 1996) (intrinsic evidence informs claim meaning)
- Markman v. Westview Instruments, Inc., 52 F.3d 967 (Fed. Cir. 1995) (claims construction is a matter of law)
- Liebel-Flarsheim Co. v. Medrad, Inc., 358 F.3d 898 (Fed. Cir. 2004) (claim terms interpreted in light of specification)
- MBO Labs., Inc. v. Becton, Dickinson & Co., 474 F.3d 1323 (Fed. Cir. 2007) (avoid importing limitations from drawings)
- Cybernetic v. American Cyanamid, 774 F.2d 448 (Fed. Cir. 1985) (standard for interpreting claims in light of specification)