World Class Technology Corp v. Ormco Corporation
769 F.3d 1120
Fed. Cir.2014Background
- Ormco owns the ’896 patent for a self-ligating orthodontic bracket and sues World Class Technology for infringement.
- The district court construed two claim terms, “support surface” and “ledge,” and the parties stipulated to non-infringement of the ’896 patent.
- The dispute centers on what constraints the claim 1 “support surface” imposes on the movable member (slide) during movement.
- The two surfaces on opposite sides of the archwire slot are termed “support surface” and “ledge,” with different orientations relative to the base surface.
- The specification emphasizes gum avoidance as the sole purpose of the acute angle between the support surface and the base plane, tying movement to a translation plane along the support surface.
- Ormco challenges the district court’s construction, arguing for a broad reading that allows the slide to interact with the ledge or otherwise during movement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ‘support surface’ is limited to slide movement during translation | Ormco: slide moves along ledge; support surface only engages at end. | World Class: support surface guides/moves the slide during translation. | Construction aligns with specification; support surface engaged during movement until closed. |
| Role of ‘ledge’ during movement of the slide | Ormco: ledge and support surface interchangeable timing. | ||
| World Class: ledge serves different role; not during full translation. | Specification distinguishes surfaces; ledge not engaged for movement until closure. | ||
| Whether claim differentiation justifies broader reading of claim 1 | Ormco: claim 6’s translation plane implies broader reach for claim 1. | World Class: independent claim 1 not coextensive with claim 6. | No; the specification confirms slide support during movement; claim 6 does not broaden claim 1. |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claim construction aided by specification and prosecution history)
- Renishaw PLC v. Marposs Società per Azioni, 158 F.3d 1243 (Fed. Cir. 1998) (interpretation to be faithful to the description of the invention)
- Thorner v. Sony Computer Entm’t Am. LLC, 669 F.3d 1362 (Fed. Cir. 2012) (en banc-style surrounding intrinsic evidence in claim meaning)
- Cybor Corp. v. FAS Techs., Inc., 138 F.3d 1448 (Fed. Cir. 1998) (de novo review of claim construction)
- Kraft Foods, Inc. v. International Trading Co., 203 F.3d 1362 (Fed. Cir. 2000) (claim differentiation and written description guide construction)
- Retractable Technologies, Inc. v. Becton, Dickinson & Co., 653 F.3d 1296 (Fed. Cir. 2011) (precedent on assertive interpretation exceeding written description)
- Bates v. Coe, 98 U.S. 31 (1878) (prosecution history and specification aid interpretation)
- White v. Dunbar, 119 U.S. 47 (1886) (specifications and claims read together to ascertain invention)
- Adams v. United States, 383 U.S. 39 (1966) (claims read in light of specifications)