PPC Broadband, Inc. v. Corning Optical Communications RF, LLC
815 F.3d 747
| Fed. Cir. | 2016Background
- PPC Broadband appeals the PTAB's final written decision in an IPR, finding claims 10–25 of the ’060 patent obvious over Matthews and Tatsuzuki.
- The Board construed the term “reside around” as “in the immediate vicinity of; near,” relying on general dictionary definitions.
- The Board concluded the Matthews/Tatsuzuki combination discloses a continuity member positioned near an external portion of the connector body, rendering the claims obvious.
- The court reviews Board legal conclusions de novo and factual findings for substantial evidence; IPR uses broadest reasonable interpretation.
- The court vacates the Board’s construction of “reside around,” adopts a different construction, and remands for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Construction of 'reside around' | PPC Broadband—encircle or surround is correct | Corning—near is correct under Board's broad definition | Board’s construction is unreasonable; encircle or surround is correct |
| Axially lengthwise contact by Tatsuzuki spring | Tatsuzuki spring does not provide lengthwise contact | Tatsuzuki spring provides contact with length beyond a point | Substantial evidence supports Tatsuzuki meeting the limitation |
Key Cases Cited
- Cuozzo Speed Techs., LLC v. Lee, 793 F.3d 1268 (Fed. Cir. 2015) (BRAI standard; IPR claim construction)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir. 1996) (claim construction canons; use of specification)
- Symantec Corp. v. Comput. Assoc. Intl., Inc., 522 F.3d 1279 (Fed. Cir. 2008) (linguistic differentiation of terms; canons of construction)
- Baran v. Medical Device Techs., Inc., 616 F.3d 1309 (Fed. Cir. 2010) (scope of claim construction; not all claims cover all embodiments)
- Funai Elec. Co. v. Daewoo Elecs. Corp., 616 F.3d 1357 (Fed. Cir. 2010) (patent specification informs claim scope)
- In re Sullivan, 498 F.3d 1345 (Fed. Cir. 2007) (standard of review in IPR/appeals)
- Randall Mfg. v. Rea, 733 F.3d 1355 (Fed. Cir. 2013) (obviousness analysis; underlying factual findings)