Rail Scale Inc v. Coastal Rail Scales L L C
2:22-cv-00153
W.D. La.Dec 9, 2024Background
- Rail Scale, Inc. (RSI) and Coastal Rail Scales, LLC (Coastal) are competitors providing calibration for railcar weighing systems.
- RSI owns U.S. Patent No. 10,996,100 B2 (“’100 Patent”), covering a portable apparatus/method for calibrating rail scales, allowing transport by road rather than rail.
- RSI alleges Coastal’s calibration system and service infringes several claims of the ’100 Patent, seeking damages and an injunction.
- Coastal denies infringement, claims the patent is invalid and unenforceable, and says its system, acquired from Balanced Railway Certification, LLC (BRC), was publicly used before RSI’s patent filing.
- This opinion resolves the claim construction (i.e., the meaning of disputed terms in the patent) after a Markman hearing, referencing claim constructions from related Texas and Tennessee cases for consistency.
Issues
| Issue | Plaintiff's Argument (RSI) | Defendant's Argument (Coastal) | Held |
|---|---|---|---|
| Whether various claim terms should have broad or narrow constructions | Terms should be construed to cover RSI’s patented methods broadly | Terms should be narrowly construed, avoiding coverage of Coastal’s prior/art system | Adopted constructions generally consistent with prior related cases, using plain or ordinary meaning where appropriate and clarifying certain terms |
| Whether accused product infringes the '100 patent | Coastal’s system uses methods and apparatus falling within the patent claims | Coastal’s system was in public use prior and is materially identical to pre-patent equipment; no infringement | Not resolved at this stage; ruling limited to claim construction |
| Whether preambles of claims 1, 7, and 10 are limitations | Preambles are limiting and should restrict interpretation | Preambles should be disregarded/not limiting | Court holds that preambles are claim limitations |
| Consistency with other district courts' claim construction | Should adopt similar constructions as in TX and TN to promote clarity/public notice | Should not be bound, but acknowledges prior interpretations | Court aligns constructions with prior cases for consistency |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (sets forth guiding principles for claim construction in patent law)
- Rambus Inc. v. Infineon Techs. Ag, 318 F.3d 1081 (Fed. Cir. 2003) (prohibits importing unstated limitations into claim language)
- JVW Enters., Inc. v. Interact Accessories, Inc., 424 F.3d 1324 (Fed. Cir. 2005) (written description should not limit claims unless specification requires)
- Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co., Ltd., 535 U.S. 722 (U.S. 2002) (construing claims consistently is necessary for public notice function)