Arlington Industries, Inc. v. Bridgeport Fittings, Inc.

Arlington Industries, Inc. v. Bridgeport Fittings, Inc.
Docket No. 2010-1025
January 20, 2011
RADER, LOURIE (concur-in-part, dissent-in-part), MOORE

This appeal relates to the meaning of the claim term “spring metal adaptor” for electrical junction boxes that was construed differently by two different courts in concomitant litigations.  One court construed the term to mean “an adaptor made of spring metal” while the other required it to contain a “’split,’ such that the diameter of the adaptor can easily expand or contract”.  The FC vacated the “split” requirement as being improperly imported into the claims from the specification, agreeing with Arlington (e.g., Phillips, FC 2005;, FC 2008).  Bridgeport argued that the “split” limitation should be part of the terms by “implication” from the specification (e.g., Irdeto, FC 2004; SciMed, FC 2001 (“written description can provide guidance…even if the guidance is not provided in explicit definitional format”).  However, the FC found that only one of the four embodiments and the drawings are consistent with that definition (no restrictive reading without “a clear intention to limit the claim scope using words of expressions of manifest exclusion or restriction” (MBO Labs, FC 2007; Martek, FC 2009; Liebel-Flarsheim, FC 2004).  It also found that limitation would “improperly discount[] substantive differences between the claims” (Phillips, FC 2005; Curtiss-Wright, FC 2006 (claim differentiation)).  That definition was also found to conflict with the prosecution history (Phillips, FC 2005 (“prosecution history can often inform the meaning of the claim language”)).  Thus, the panel vacated the DC summary judgment and remanded the case.   Judge Lourie’s dissent argued that the claims should be limited based on the specification (e.g., “[t]he specification is the heart of the patent. In colloquial terms, ‘you should get what you disclose.’”)

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