Plantronics, Inc. v. Aliph, Inc.
724 F.3d 1343
Fed. Cir.2013Background
- Plantronics sues Aliph for infringement of the ’453 patent concerning a concha headset stabilizer.
- District court granted summary judgment of noninfringement and invalidity on asserted claims 1 and 10, and held the claims obvious.
- The court construed “stabilizer support member” and “concha stabilizer” and found the asserted claims not infringed and invalid as obvious.
- The district court’s construction narrowed the terms to elongated structures and relied on a PTO restriction-election in prosecution.
- The Federal Circuit vacates and remands: it reverses the claim constructions, reverses the obviousness ruling, and remands for further proceedings.
- The case concerns a concha-stabilized headset that engages the tragus, antitragus, and upper concha with a receiver between the tragus and anti-tragus.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper construction of stabilizer term scope | Plantronics argues broad, non-elongated meaning | Aliph argues elongated, “longer than wide” structures | Terms not limited to elongated structures; broadly construed and remanded |
| Noninfringement finding proper | Plantronics bears infringement under broad constructions | Aliph contends no infringement under the district court’s terms | Infringement issue remanded after construing term scope |
| Obviousness ruling proper given objective evidence | Plantronics presented objective indicia of nonobviousness | Lieber/Komoda combination with generalized rationale shows obviousness | Obviousness ruling reversed; objective indicia must be considered, leading to remand |
| Consideration of objective indicia prior to invalidity ruling | Court failed to weigh copying/commercial success | District court relied on common sense | Reversal; require consideration of all objective evidence before final obviousness ruling |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claim construction framework; statutes/specification/prosecution history relevance)
- Omega Eng’g, Inc. v. Raytek Corp., 334 F.3d 1314 (Fed. Cir. 2003) (prosecution-history disclaimer can narrow claim scope)
- Cross Med. Prods., Inc. v. Medtronic Sofamor Danek, Inc., 424 F.3d 1293 (Fed. Cir. 2005) (combination of old elements can yield an invention; objective indicia guidance)
- KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398 (Supreme Court 2007) (flexible approach to obviousness; common sense as a factor)
- Green Edge Enters., LLC v. Rubber Mulch Etc. LLC, 620 F.3d 1287 (Fed. Cir. 2010) (objective indicia must be weighed with the obviousness analysis)