Ruckus Wireless, Inc. v. Innovative Wireless Solutions, LLC
824 F.3d 999
| Fed. Cir. | 2016Background
- IWS owns three continuations of the ‘‘Terry patents’’ concerning providing LAN access over long distances by using a collision-avoidance scheme controlled by master/slave modems. The specification describes telephone subscriber (two‑wire) lines and other twisted‑pair wiring; it does not discuss wireless links.
- IWS sued many businesses for alleged infringement based on Wi‑Fi equipment; Ruckus and Cisco sought declaratory judgment of non‑infringement in the W.D. Tex. action.
- Central claim language at issue: the patents’ independent claims recite communication via a “bidirectional communications path.” Dependent claims sometimes recite “two‑wire” or “two‑wire telephone subscriber line.”
- The district court construed “communications path” to mean a wired path (specifically twisted‑pair wiring too long for 10BASE‑T), concluding the specification focused on wired/telephone lines. The parties then stipulated to final judgment of non‑infringement.
- The Federal Circuit affirmed, holding the intrinsic record precludes reading wireless communications into “communications path” and relying on claim context, specification language (including title and repeated references to telephone/two‑wire lines), and the written‑description canon.
Issues
| Issue | Plaintiff's Argument (IWS) | Defendant's Argument (Ruckus) | Held |
|---|---|---|---|
| Whether “communications path” includes wireless communications | Term has its plain and ordinary meaning that includes wireless; dependent‑claim limitations don’t require excluding wireless | The intrinsic record shows the invention is directed to wired paths; “communications path” lacks a plain‑and‑ordinary meaning that necessarily includes wireless | The term is limited to wired communications as construed by the district court; affirmed |
| Whether intrinsic evidence permits importing a wired limitation into the claims | It is improper to read a limitation from the embodiments into the claims; dependent claims labeling some paths as “two‑wire” implies broader independent claim | The specification repeatedly and expressly focuses on telephone/two‑wire lines and the problem addressed (long‑distance wired links), supporting a wired limitation | Intrinsic evidence (title, specification, embodiments) supports treating the communications path as wired; no extrinsic evidence showed otherwise |
| Whether extrinsic evidence was required or warranted | The plain meaning was uncontested below, so no extrinsic evidence was needed; remand should be allowed if court deems it necessary | No extrinsic evidence was offered and the intrinsic record controls; no need to consult extrinsic materials | The majority found no extrinsic evidence and proceeded on intrinsic record (affirming); dissent would remand for possible extrinsic fact‑finding |
| Whether claim construction should be guided by preserving validity (written‑description) | IWS: unclear but contends plain meaning governs; written‑description concerns cannot justify importing a limitation absent clear intrinsic support | Ruckus: limiting to wired avoids potential written‑description problems and accords with specification | Majority applied the validity‑preserving canon to support the wired construction; dissent argued validity should not drive construction absent ambiguity |
Key Cases Cited
- Teva Pharm. USA, Inc. v. Sandoz, Inc., 135 S. Ct. 831 (2015) (claim construction may require subsidiary factual findings and consideration of extrinsic evidence)
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claims given their plain and ordinary meaning to a person of ordinary skill; specification is primary source)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir. 1996) (intrinsic evidence is primary in claim construction)
- Gentry Gallery, Inc. v. Berkline Corp., 134 F.3d 1473 (Fed. Cir. 1998) (claims cannot be broader than their supporting disclosure)
- Liebel‑Flarsheim Co. v. Medrad, Inc., 358 F.3d 898 (Fed. Cir. 2004) (absent clear disclaimer, inventor’s focus on a particular use does not limit claim scope)
- Hill‑Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367 (Fed. Cir. 2014) (limits on departing from plain meaning: lexicography or clear disavowal of scope)