Schuyleman v. Barnhart Crane and Rigging Co
2:23-cv-00562
W.D. Wash.Oct 9, 2024Background
- The dispute involves the construction of claim terms in U.S. Patent No. 8,317,244, related to a method for safely positioning objects, like wall panels, into building openings during construction.
- Plaintiff Jay Schuyleman is the patent holder and asserts that the plain and ordinary meanings of several terms suffice; Defendant Barnhart seeks narrower technical constructions or contends certain terms are indefinite.
- The court held a Markman (claim construction) hearing and reviewed both parties’ briefs, supporting evidence, and argument.
- None of the claim terms were expressly defined by the patent or disavowed their ordinary scope in the patent or prosecution history.
- The court resolved disputes on eight claim terms, focusing primarily on aligning meanings with how a person of ordinary skill in the art (POSITA) would interpret them in light of the patent's context.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Indefiniteness of "offset hoisting apparatus" | Term is definite with ordinary meaning | Term is indefinite; if not, preamble is limiting | No ruling on indefiniteness; preamble is limiting |
| Construction of "rigid boom" | Plain/ordinary meaning; not fixed length | Must be a support arm with a fixed length | "A beam that is largely inflexible"; not limited to fixed length |
| Construction of "front mount"/"rear mount" | Closest to load/opposite end | Must reference position relative to center of gravity | "Mount closest to distal/proximal end of rigid boom" |
| Construction of "front/rear boom aperture" | Openings for boom to travel through | Holes whose surface matches boom's exterior | "Openings through which the rigid boom may travel" |
| Construction of "confining the boom" | Means restricting to forward/backward movement | Restricts movement except along long axis, contacting sides | "Restricting the boom to forward and backward movement" |
| Construction of "slidable movement" | Needs no construction; "slides" is plain | Requires movement along relative surfaces of components | No construction needed; plain meaning suffices |
| Construction of "therethrough" | Just means "through" | Means entering one side, exiting the other | "Allowing the rigid boom to slide through one side and out the other" |
| Construction of "fixed with" | Plain/ordinary meaning; just "attached to" | Means directly engaged to and not in | "Attached in some way to" |
Key Cases Cited
- Markman v. Westview Instruments, Inc., 517 U.S. 370 (claim construction is a matter for the court)
- O2 Micro Int’l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351 (court must resolve claim scope disputes)
- Phillips v. AWH Corp., 415 F.3d 1303 (words of a claim get their ordinary and customary meaning; specification usually dispositive)
- Thorner v. Sony Comput. Ent. Am. LLC, 669 F.3d 1362 (exceptions to ordinary meaning: lexicography or clear disavowal)
- Liebel-Flarsheim Co. v. Medrad, Inc., 358 F.3d 898 (claims are not limited to a single embodiment unless required)