Samuel Stamping Technologies, LLC v. Therma-Tru Corp., 3:20-cv-01011

Samuel Stamping Technologies (SST) sued Therma-Tru Corp. for infringing three design patents relating to ornamental door skin designs.
The patents at issue are D557,427 (D427), D625,023 (D023), and D635,276 (D276), each covering specific aesthetic door features.
Therma-Tru previously challenged the patents as indefinite, but a jury found in favor of SST on that issue.
The court was asked to construe disputed terms in the design patents, particularly regarding which features are ornamental vs. functional.
Both parties submitted proposed claim constructions, with Therma-Tru pushing for exclusions of arguably functional features.

Issue	Plaintiff's Argument	Defendant's Argument	Held
How to construe the scope of the design patents	Claim scope includes stated ornamental features	Functional features (panel size/placement) should not be part of claimed design	Court adopted SST's constructions, rejected exclusions
Should prior art limit/supplement claim construction	No need for detailed verbal differentiation from prior art	Prior art should inform claim construction and limit scope	Court found prior art differences best left to jury
Should prosecution history impact claim construction	Current references to drawings already suffice	Specific statements from prosecution should guide interpretation	Court found additional references unhelpful
Are panel size/placement features purely functional or ornamental	Features are part of the overall design	These features are functional, dictated by industry standards	Court held these cannot be excluded from design claim

Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (sets the framework for claim construction using ordinary meaning to a person skilled in the art)
Finisar Corp. v. DirecTV Group, Inc., 523 F.3d 1323 (Fed. Cir. 2008) (emphasizes use of intrinsic evidence in claim interpretation)
Elmer v. ICC Fabricating, Inc., 67 F.3d 1571 (Fed. Cir. 1995) (design patents protect nonfunctional, ornamental aspects)
KeyStone Retaining Wall Sys., Inc. v. Westrock, Inc., 997 F.2d 1444 (Fed. Cir. 1993) (design patent protection is limited to ornamental design)
Egyptian Goddess, Inc. v. Swisa, Inc., 543 F.3d 665 (Fed. Cir. 2008) (preferable not to construe design patents with detailed verbal descriptions)
OddzOn Prods., Inc. v. Just Toys, Inc., 122 F.3d 1396 (Fed. Cir. 1997) (claims must identify nonfunctional aspects when both functional and nonfunctional features present)
Sport Dimension, Inc. v. Coleman Co., 820 F.3d 1316 (Fed. Cir. 2016) (ornamental design cannot exclude structural elements simply because they are functional)