The Chamberlain Group, Inc. v. Techtronic Industries Co. Ltd.
676 F. App'x 980
| Fed. Cir. | 2017Background
- CGI owns U.S. Patent No. 7,224,275, directed to garage-door openers that wirelessly transmit status information; claim 1 recites a controller, a movable-barrier interface, and a wireless status-condition data transmitter that transmits a status-condition signal identifying the operator.
- TTI began selling the Ryobi GD200 garage door opener (Ryobi GDO) through Home Depot in 2016; CGI sued for patent infringement and moved for a preliminary injunction.
- The district court granted a preliminary injunction as to claims 1 and 5, construing the claim term “controller” to require a "self-aware" controller that does not rely on external sensors, and concluded CGI was likely to succeed on the merits and would suffer irreparable harm.
- The district court relied principally on its "self-aware controller" construction to find that TTI had not raised a substantial question of invalidity based on prior art.
- TTI appealed, challenging claim construction and the injunction; the Federal Circuit reviewed claim construction de novo and vacated the preliminary injunction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper construction of "controller" in claim 1 | CGI: "controller" refers to internal/potential operational status conditions (i.e., a self-aware controller) | TTI: claim language and specification permit a controller that uses external sensors; no self-aware requirement | The Federal Circuit: "controller" does not require a self-aware controller; specification contemplates both self-aware and sensor-dependent controllers; district court's construction was erroneous |
| Effect of dependent claim 2 (sensors) on claim 1 scope | CGI: differences between claims support a self-aware reading of claim 1 | TTI: presence of sensors in dependent claim 2 does not exclude sensors from claim 1; dependent claims incorporate limitations | Held: dependent claim 2 does not show claim 1 excludes sensors; district court misapplied dependent/independent claim logic |
| Whether TTI raised a substantial question of invalidity | CGI: district court properly found prior art did not teach a self-aware controller; TTI did not raise substantial question | TTI: with correct construction, prior art raises substantial question of invalidity | Held: Because the district court’s sole basis for rejecting invalidity was the incorrect construction, TTI raised a substantial question of invalidity and CGI failed to show likelihood of success |
| Appropriateness of preliminary injunction | CGI: all four Winter factors satisfied (likelihood of success, irreparable harm, balance, public interest) | TTI: incorrect claim construction undermines likelihood of success; also contested irreparable harm | Held: Vacated the preliminary injunction because likelihood of success was not established under the correct claim construction; remanded for further proceedings |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claim terms given ordinary and customary meaning; intrinsic record is primary guide)
- Teva Pharm. U.S.A., Inc. v. Sandoz, Inc., 135 S. Ct. 831 (2015) (deferential review for subsidiary factual findings in claim construction; ultimate construction reviewed de novo)
- Sanofi–Synthelabo v. Apotex, Inc., 470 F.3d 1368 (Fed. Cir. 2006) (preliminary injunction standards and the requirement to show likelihood of success and irreparable harm)
- Genentech, Inc. v. Novo Nordisk A/S, 108 F.3d 1361 (Fed. Cir. 1997) (preliminary injunction should not issue where accused infringer raises a substantial question of invalidity)
- Amazon.com, Inc. v. Barnesandnoble.com, Inc., 239 F.3d 1343 (Fed. Cir. 2001) (abuse of discretion standard for preliminary injunctions)