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Arlington Industries, Inc. v. Bridgeport Fittings

February 25, 2008

ARLINGTON INDUSTRIES, INC., PLAINTIFF
v.
BRIDGEPORT FITTINGS, INC., DEFENDANT
BRIDGEPORT FITTINGS, INC., PLAINTIFF
v.
ARLINGTON INDUSTRIES, INC., DEFENDANT



The opinion of the court was delivered by: Christopher C. Conner United States District Judge

(Judge Conner)

MEMORANDUM

Presently before the court in this patent infringement action are the parties' contentions regarding the proper interpretation of claim terms. The issues are ripe for disposition, and the court will enter an order pursuant to Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996).

I. Factual Background

The patent sub judice (patent no. Re. 5,266,050, hereinafter "the '050 patent") covers quick connect fittings for electrical junction boxes. (See Doc. 284, Ex. 3.) It is a continuation of patent no. 5,171,164 (hereinafter, "the '164 patent") and issued to employees of Arlington Industries, Inc. ("Arlington").*fn1 (See id.) The patent describes a new type of electrical connector to replace previous units that required the use of two hands to screw the device into an electrical junction box. (See id.)

The patent encompasses eight claims, only one of which Bridgeport Fittings, Inc. ("Bridgeport"), is alleged to have infringed.*fn2 The claim at issue-claim 8-reads as follows:

A quick connect fitting for an electrical junction box comprising: a hollow electrical connector through which an electrical conductor may be inserted having a leading end thereof for insertion in a hole in an electrical junction box; a circular spring metal adaptor surrounding said leading end of said electrical connector which has a leading end, a trailing end, and an intermediate body; at least two outwardly sprung members carried by said metal adaptor near said trailing end of said adaptor which engage the side walls of the hole in the junction box into which said adaptor is inserted; at least two spring locking members carried by said metal adaptor that spring inward to a retracted position to permit said adaptor and locking members to be inserted in a hole in an electrical junction box and spring outward to lock said electrical connector from being withdrawn through the hole; and an arrangement on said connector for limiting the distance said connector can be inserted into the hole in the junction box. (Id. at col. 10.) The '050 patent also includes a detailed specification, containing descriptions and illustrations of various embodiments of the invention. (See id., Ex. 3.)

II. Discussion

An inventor may assert ownership only over those designs encompassed within the claims section of the patent. See 35 U.S.C. § 112; Pfaff v. Wells Elecs., Inc., 525 U.S. 55, 63 (1998); Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed. Cir. 2005), cert. denied, 546 U.S. 1170 (2006). The proper construction of claims is a question of law. Markman v. Westview Instruments, Inc., 52 F.3d 967, 979 (Fed. Cir. 1995) (en banc), aff'd, 517 U.S. 370 (1996). It requires the court to determine the "ordinary and customary meaning" of the claim terms as they would be understood by "a person of ordinary skill in the art in question at the time of the invention." Phillips, 415 F.3d at 1312-13; see also Arlington Indus., Inc. v. Bridgeport Fittings, Inc., 290 F. Supp. 2d 508, 519 (M.D. Pa. 2003). This meaning should be discerned, if possible, from intrinsic evidence, i.e., the language of the patent and its prosecution history. See Home Diagnostics, Inc. v. Lifescan, Inc., 381 F.3d 1352, 1355-56 (Fed. Cir. 2004); Novartis Pharm. Corp. v. Abbott Labs., 375 F.3d 1328, 1334-35 (Fed. Cir. 2004). The court may use extrinsic evidence, e.g., dictionaries, treatises, and expert testimony, to aid in claim construction, but such evidence is "less significant than the intrinsic record" and is "unlikely to result in a reliable interpretation of patent claim scope unless considered in the context of the intrinsic evidence." Phillips, 415 F.3d at 1317-19, 1324; see also Home Diagnostics, 381 F.3d at 1355-56.

In using the language of the patent itself, "claims 'must be read in view of the specification,' . . . [which] is the single best guide to the meaning of a disputed term." Phillips, 415 F.3d at 1315 (citing Markman, 52 F.3d at 979 and Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1582 (Fed. Cir. 1996). Likewise, "the claims themselves provide substantial guidance as to the meaning of particular claim terms." Id. at 1314 (citing Vitronics, 90 F.3d at 1582). To this end, the context in which a claim term is used, the language of other claims in the patent, and the differences among claims can assist the court in construing disputed claim terms. See id. at 1314-15.

Four terms of claim 8 of the '050 patent are in dispute: "circular," "spring metal adaptor," "outwardly sprung members," and "carried by said metal adaptor near said trailing end of said adaptor."*fn3 (See Docs. 283, 286, 298, 308.) The court will examine them seriatim.

A. "Circular"

The term "circular" is used in all claims of the '050 patent to describe the spring metal adaptor. Bridgeport contends that "circular" means "cylindrical or tubular, such that [the adaptor's] diameter is substantially constant along its axial length."*fn4 (Doc. 283 at 7.) Arlington argues that this term should be construed to mean "hav[ing] circular cross sections." (Doc. 286 at 15.) The evidence supports Arlington's construction.

To support its proposed construction, Bridgeport notes that the spring metal adaptor is a three-dimensional object and that Arlington's proposed construction focuses on a two-dimensional definition. Bridgeport argues that Arlington implicitly defined "circular" in the specification of the '050 patent as "cylindrical or tubular, such that its diameter is substantially constant along its axial length" because the specification consistently depicts and describes an adaptor with this characteristic. See Phillips, 415 F.3d at 1321 ("[T]he specification 'acts as a dictionary when it expressly defines terms used in the claims or when it defines terms by implication.'" (citations omitted)). Along with emphasizing various figures depicting a cylindrical adaptor (see, e.g., Doc. 284, Ex. 3, figs. 11, 15), Bridgeport notes that a "laid-out" view of the adaptor shows a flat rectangular strip of metal (see id., fig. 10). Bridgeport contends that "[b]asic geometry dictates that a 'circular' adaptor formed from a rectangle must take the shape of a cylinder."*fn5

(Doc. 283 at 8.) Bridgeport also points to language in the specification and claim 1 that describes the adaptor with a single, constant diameter:

The spring steel adaptor 20 typically has an outer diameter of 0.845 inches in its relaxed state. . . .

After being formed into a circular shape, the inside diameter of the spring steel adaptor 20 of FIGS. 11, 12, and ...


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