Ge Lighting Solutions, LLC v. Agilight, Inc.
750 F.3d 1304
| Fed. Cir. | 2014Background
- GE sued AgiLight for infringing five patents covering LED string-light components and an overmolding process; district court granted summary judgment of noninfringement for several asserted claims and entered a stipulation of noninfringement for two patents based on a claim-construction ruling.
- The '140 and '771 patents claim LED string-light engines that include an "IDC connector"—a connector that makes electrical contact by displacing insulation on a conductor; the district court construed "IDC connector" narrowly by importing structural limits from the specification and dependent claims.
- The '896 patent claims an optical element with a "substantially ellipsoidal inner profile" and "generally spherical outer profile"; parties stipulated to geometric definitions but disputed whether those profile requirements must apply to entire profiles or may be satisfied by portions.
- The '055 patent claims an overmolding method using an "annular gasket" surrounding an LED; district court construed "annular gasket" to require a ring-like opening and held AgiLight’s dome-shaped lens did not meet that limitation.
- The Federal Circuit reviewed claim construction de novo and regional-circuit summary judgment de novo, reversing summary judgment for the '140, '771, and '896 patents and affirming the '055 patent ruling.
Issues
| Issue | Plaintiff's Argument (GE) | Defendant's Argument (AgiLight) | Held |
|---|---|---|---|
| Proper construction of "IDC connector" ('140, '771) | IDC connector has its plain meaning: any connector that displaces insulation to make contact; do not import structural limits from one embodiment or dependents. | Term should be limited to the specialized embodiment disclosed (four terminals, two-part snap housing, specific wire count, etc.). | Reversed district court: adopt plain meaning—connector that displaces insulation to make contact; do not import embodiment/dependent-claim limitations. |
| Scope of "substantially ellipsoidal inner profile" ('896) | The stipulated geometric definition need not require the entire inner surface to be ellipsoidal; a portion can satisfy the claim—do not exclude the disclosed embodiment. | The profile terms must apply to the entire inner and outer surfaces of the dome-shaped optical element; partial-profile reading impermissibly expands claim scope. | Reversed summary judgment: claim can be met if a portion of the inner profile is substantially ellipsoidal; genuine fact dispute exists. |
| Scope of "generally spherical outer profile" ('896) | Stipulated definition (points generally equidistant from center) can be satisfied by the accused product’s outer surface; cross-sections create a genuine dispute. | Accused lens outer surface is not generally spherical across the full profile; expert testimony shows non-sphericity. | Reversed summary judgment: evidence (including accused expert’s cross-sections) creates a genuine dispute as to whether the outer profile is generally spherical. |
| Whether AgiLight dome is an "annular gasket" ('055) | The accused concave/dome lens can function as an annular gasket for sealing during overmolding. | The court’s construction requires an annular opening (ring-shaped gasket cut from sheet); a dome lacks the required opening. | Affirmed summary judgment: under the correct construction an "annular gasket" requires an opening; AgiLight’s dome-shaped lens lacks that opening and is not an annular gasket. |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir.) (en banc) (claims construed in light of specification and prosecution history)
- Thorner v. Sony Computer Entm’t Am. LLC, 669 F.3d 1362 (Fed. Cir.) (standards for lexicography and disavowal)
- Liebel-Flarsheim Co. v. Medrad, Inc., 358 F.3d 898 (Fed. Cir.) (do not import preferred-embodiment limitations into claims)
- MBO Labs., Inc. v. Becton, Dickinson & Co., 474 F.3d 1323 (Fed. Cir.) (avoid claim constructions that exclude sole disclosed embodiment)
- TorPharm, Inc. v. Ranbaxy Pharms., Inc., 336 F.3d 1322 (Fed. Cir.) (prosecution statements can limit claim scope)
- Omega Eng’g, Inc. v. Raytek Corp., 334 F.3d 1314 (Fed. Cir.) (prosecution disclaimer prevents recapture of surrendered scope)