Clare v. Chrysler Group LLC
819 F.3d 1323
Fed. Cir.2016Background
- Clare (Scott Clare, Neil Long, and Innovative Truck Storage, Inc.) accused Chrysler of infringing U.S. Pat. Nos. 6,499,795 and 7,104,583 by selling Dodge Ram trucks with the RamBox storage system.
- The patents claim a hidden side-bed storage compartment accessed via a hinged side panel configured so the storage is not obvious from the truck’s outward appearance (only two vertical cut lines visible in the specification’s embodiment).
- The district court construed the “external appearance” limitations as requiring that the storage box not be obvious from the outward appearance of the pickup.
- Chrysler moved for summary judgment of non-infringement as to claims containing that limitation; the district court granted summary judgment, finding the RamBox’s visible seams, lock, stamped lettering, and panel made the storage obvious.
- Clare appealed the claim construction and the grant of summary judgment (Clare did not pursue the district court’s doctrine-of-equivalents ruling on appeal).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Claim construction of “external appearance” limitation | Term needs no construction; focuses only on visibility of the internal storage box, not the external hinged panel | Term encompasses the outward appearance including the external hinged panel used to access storage | Court affirmed construction: requires that the storage box (including the hinged panel) not be obvious from the outward appearance |
| Whether two formulations ("has an external appearance of a conventional pickup" vs. "substantially the external appearance") have different scope | These are distinct and should be construed separately; "substantially" differs from identical appearance | Both phrases read in light of the spec; they have the same meaning for these patents | Court held both mean the storage is not obvious from outward appearance; specification precludes reading the claims to require literal identity with an unmodified truck |
| Whether the construction improperly imports the inventor’s theft-deterrent purpose into the claims | Construction impermissibly injects the theft-deterrent purpose | Construction requires non-obvious outward appearance, not the purpose; purpose in spec explains why non-obviousness matters | Court held no improper importation of purpose; non-obvious outward appearance is a claim requirement independent of motive |
| Summary judgment of non-infringement under the adopted construction | Evidence (expert report) raises factual disputes about whether the panel is non-obvious (contours, paint, angles) and visibility from some angles | Admitted deposition testimony and photos show obvious hinged panel, visible lock, seams, and RAMBOX stamping; no reasonable juror could find non-obviousness | Court affirmed summary judgment: even taking expert facts in plaintiff’s favor, RamBox’s outwardly visible features render the claimed external-appearance limitation unmet |
Key Cases Cited
- Georgia-Pac. Corp. v. U.S. Gypsum Co., 195 F.3d 1322 (Fed. Cir.) (two-step infringement framework: claim construction then comparison to accused device)
- Teva Pharm. USA Inc. v. Sandoz, Inc., 135 S. Ct. 831 (U.S.) (deference framework for claim construction when extrinsic evidence is used)
- Pacing Techs., LLC v. Garmin Int’l, Inc., 778 F.3d 1021 (Fed. Cir.) (review standard when construction is based on intrinsic evidence)
- Moore v. Holbrook, 2 F.3d 697 (6th Cir.) (summary judgment reviewed de novo in Sixth Circuit)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S.) (summary judgment standard and view of evidence inferences)
- Aventis Pharm. Inc. v. Amino Chems. Ltd., 715 F.3d 1363 (Fed. Cir.) (meaning of “substantially” in claim language)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir.) (claims should not be interpreted to exclude a preferred embodiment)
- E-Pass Techs., Inc. v. 3Com Corp., 343 F.3d 1364 (Fed. Cir.) (warning against importing a purpose into claim language)
- Biogen, Inc. v. Berlex Labs., Inc., 318 F.3d 1132 (Fed. Cir.) (prosecution statements cannot expand or contradict the specification)