STANT USA CORP. v. BRIGGS & STRATTON CORPORATION
1:13-cv-01908
S.D. Ind.Aug 25, 2015Background
- Stant USA owns U.S. Patent No. 7,261,093 directed to fuel caps that use activated carbon to adsorb hydrocarbon vapors and either passively or actively purge them.
- Briggs & Stratton makes and sold "carbon-in-cap" fuel caps and is accused by Stant of infringing Claims 1 and 22 of the '093 patent; Briggs counterclaims that a Stant cap infringes Claim 33 of its U.S. Patent No. 6,595,696.
- The patents describe passageways, adsorbent (carbon) beds, and different purging modes: passive (pressure/temperature-driven) and active (engine-vacuum-driven via a purge hose).
- Parties disputed construction of four terms in the '093 patent (e.g., "fuel vapor-conducting passageway," direction/placement of adsorbent, "vapor discharge channel") and two terms in the '696 patent ("vent conduit" and sizing language eliminating a vapor conduit to engine intake).
- The court held a Markman hearing and applied Phillips/Vitronics claim-construction principles, prioritizing claim language and the specification over extrinsic evidence.
Issues
| Issue | Plaintiff's Argument (Stant) | Defendant's Argument (Briggs) | Held |
|---|---|---|---|
| Meaning of “fuel vapor-conducting passageway” (Claims 1 & 22) | Passageway runs from fuel vapor entry port to atmospheric air entry port — a path/channel by which fuel vapor is conveyed | Passageway ends at adsorbent (carbon) i.e., does not necessarily extend to atmospheric port | Court adopted Stant: a path/channel conveying fuel vapor (connects entry and atmospheric ports) |
| Whether first/second directions may contain adsorbent (Claims 1 & 22) | No limitation — adsorbent need not be limited to the third direction; claim language permits other placements | Limit first and second directions to substantially no adsorbent based on specification embodiment | Court adopted Stant’s construction: claim language controls; no such limitation imported from specification |
| “Fuel vapor passing along the third direction is filtered before exiting the vapor passageway” (Claim 22) | (Parties stipulated) hydrocarbons are adsorbed by adsorbent (e.g., carbon) when vapor passes in the third direction | (Agreed) | Court adopted the parties’ agreed construction: hydrocarbons are adsorbed in the third direction |
| “a vapor discharge channel” (Claim 22) | Plain meaning: a passage that vents/discharges vapor (filtered or purged) | Limit to passage carrying hydrocarbon-laden vapor purged from the adsorbent (implies inward flow to tank) | Court adopted plain meaning; refused Briggs’s limiting construction |
| “a vent conduit providing fluid communication between the fuel tank and the evaporative emission device” (Claim 33, '696) | Define “conduit” as tube/pipe/hose (Stant sought an explicit structural term) | No special construction necessary; plain meaning guided by claim function | Court held no additional limitation; plain and ordinary meaning applies (function described in claim controls) |
| "device volume and tank volume ... such that a vapor conduit ... to an engine intake assembly is eliminated" (Claim 33, '696) | Stant: reads as elimination of the vapor conduit itself and attempted comparison to a pre-existing/accused system | Briggs: means the need for a separate vapor conduit to the engine intake is eliminated (consistent with spec language that the vapor line is unnecessary) | Court adopted Briggs’s formulation: the need for a vapor conduit to engine intake is eliminated (consistent with the specification) |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (en banc) (claim terms given ordinary meaning to a POSA and specification is primary guide)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir.) (specification is the single best guide to claim meaning)
- Renishaw PLC v. Marposs Societa' per Azioni, 158 F.3d 1243 (Fed. Cir.) (construction aligning with claim language and specification is preferred)
- Enercon GmbH v. Int’l Trade Comm’n, 151 F.3d 1376 (Fed. Cir.) (claims not limited to a single disclosed embodiment)
- SRI Int’l, Inc. v. Matsushita Elec. Corp., 775 F.2d 1107 (Fed. Cir.) (describing limits of confining claims to preferred embodiment)
- Kara Tech., Inc. v. Stamps.com Inc., 582 F.3d 1341 (Fed. Cir.) (patentee entitled to full scope of claimed language)
- ERBE Elektromedizin GmbH v. Int’l Trade Comm’n, 566 F.3d 1028 (Fed. Cir.) (specification can be dispositive in claim construction)