Mettler-Toledo, Inc. v. B-Tek Scales, LLC, 671 F.3d 1291

Mettler-Toledo sued B-Tek for infringement of the ’547 and ’052 patents related to weighing technology.
The district court construed several means-plus-function terms, including a key A/D converter limitation in the ’547 patent.
The jury found no literal or DOE infringement of the ’547 patent and that the ’052 patent was not infringed and invalid for obviousness.
Mettler challenged the JMOL denials on infringement and invalidity; B-Tek cross-appealed sanctions denial.
The court affirmed the district court’s claim construction for the ’547 patent, upheld the jury’s finding of no infringement and the invalidity of the ’052 patent, and affirmed the sanctions ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the claim construction for the ’547 patent correct?	Mettler contends the district court erred by limiting to a multiple slope A/D converter.	B-Tek argues the specification links the functions to the multiple slope A/D converter, not a generic converter.	Yes; construction limited to multiple slope A/D converter.
Was there substantial evidence of noninfringement of the ’547 patent?	Mettler argues delta-sigma A/D is equivalent to multiple slope A/D.	B-Tek presented substantial differences between converters; not equivalent.	Yes; district court’s JMOL affirmed; no infringement.
Was the ’052 patent properly found invalid for obviousness based on Avery?	Mettler asserts Avery does not teach load-position correction for the claimed invention.	B-Tek maintains Avery teaches load-position correction and supports obviousness.	Yes; substantial evidence supports obviousness based on Avery.
Does Avery teach away from the claims of the ’052 patent?	Mettler argues Avery discourages the claimed compensated multi-load-cell approach.	B-Tek contends Avery does not teach away and is consistent with claim 7.	No; Avery does not teach away.
Did the district court abuse its discretion in sanctions ruling against Mettler?	B-Tek asserts discovery violations warranted sanctions.	Mettler argues lack of harm and relevance undermines sanctions.	No; sanctions ruling affirmed.

Medical Instrumentation & Diagnostics Corp. v. Elekta AB, 344 F.3d 1205 (Fed. Cir. 2003) (means-plus-function structure limited to disclosed embodiments)
B. Braun Medical Inc. v. Abbott Labs., 124 F.3d 1419 (Fed. Cir. 1997) (structure linkage to claimed function required)
Nomos Corp. v. Brainlab U.S.A., Inc., 357 F.3d 1364 (Fed. Cir. 2004) (single-embodiment means-plus-function limitation scope)
Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claim construction uses ordinary meaning in context)
Cybor Corp. v. FAS Techs., Inc., 138 F.3d 1448 (Fed. Cir. 1998) (de novo review of claim construction)
Upjohn Co. v. Mova Pharm. Corp., 225 F.3d 1310 (Fed. Cir. 2000) (prior art disclosure analysis for obviousness and teachings)
Uniloc USA, Inc. v. Microsoft Corp., 632 F.3d 1292 (Fed. Cir. 2011) (prior art disclosure questions; standards for validity findings)
Acco Brands, Inc. v. ABA Locks Mfrs. Co., 501 F.3d 1307 (Fed. Cir. 2007) (juror’s substantial evidence standard for JMOL)
Armendariz v. Pinkerton Tobacco Co., 58 F.3d 1342 (5th Cir. 1995) (standard for JMOL in regional circuit context)