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Tyco Fire Products Lp D/B/A Tyco Fire v. the Reliable Automatic Sprinkler Co.

May 16, 2011

TYCO FIRE PRODUCTS LP D/B/A TYCO FIRE SUPPRESSION & BUILDING PRODUCTS PLAINTIFF,
v.
THE RELIABLE AUTOMATIC SPRINKLER CO., INC. DEFENDANT



The opinion of the court was delivered by: Baylson, J.

MEMORANDUM ON CLAIM CONSTRUCTION

I. Introduction

On July 13, 2010, Plaintiffs Tyco Fire Products LP ("Tyco") filed a declaratory judgment action against The Reliable Automatic Sprinkler Co., Inc. ("Reliable"). Reliable holds U.S. Pat. No. 6,446,732 entitled "VELO ECOH sprinkler arrangement" ("the '732 patent"), a fire protection sprinkler system. See Pl.'s Opening, Ex. 1. Tyco seeks determinations that Tyco's Model EC-17 Area Density sprinkler does not infringe upon the '732 patent and that the claims of the '732 patent are invalid. Reliable has countersued for infringement.

Presently before this Court are the parties' briefs on claim construction pursuant to Markman v. Westview Instruments, Inc., 52 F.3d 967 (Fed. Cir.1995) (en banc), aff'd 517 U.S. 370 (1996). On March 28, 2011, the Court held argument on claim construction.

II. Legal Standards

Claim construction is a matter of law. Markman, 517 U.S. at 372. Claim terms are "generally given their ordinary and customary meaning" from the perspective of "a person of ordinary skill in the art in question at the time of the invention." Phillips v. AWH Corp., 415 F.3d 1303, 1313 (Fed. Cir. 2005) (en banc).

In some instances, the ordinary and customary meaning "as understood by a person of skill in the art may be readily apparent even to lay judges, and claim construction in such cases involves little more than the application of the widely accepted meaning of the commonly understood words." Id at 1314. A district court is not obligated to construe terms with ordinary meanings, lest trial courts be inundated with requests to parse the meaning of every word in the asserted claims. O2 Micro Int'l Ltd. v. Beyond Innovation Tech. Co., Ltd., 521 F.3d 1351, 1360--62 (Fed. Cir. 2008)

If a term's meaning is not readily apparent, the court may discern the meaning from a variety of sources, such as "the words of the claims themselves, the remainder of the specification, the prosecution history, and extrinsic evidence concerning relevant scientific principles, the meaning of technical terms, and the state of the art.'" Phillips, 415 F.3d at 1314 (citing Innova/Pure Water, Inc. v. Safari Water Filtration Sys., Inc., 381 F.3d 1111, 1116 (Fed. Cir. 2004)). Claim terms are not construed "in a vacuum [but] in the context of the written description and the prosecution history." Id. at 1313 (quoting Medrad, Inc. v. MRI Devices Corp., 401 F.3d 1313, 1319 (Fed. Cir. 2005)).

The meaning of a claim term begins with the intrinsic evidence: the claim language, the specification, and the prosecution history. The context in which the term is used within the claim may offer significant guidance, "provid[ing] a firm basis for construing the term." Id. at 1314. Term usage in one claim will also typically illuminate the meaning of the same term used in another claim. Id.

As claims are part of a larger fully integrated document, they must also be "read in view of the specification." Id. at 1315 (quoting Markman, 52 F.3d at 979). The specification is "highly relevant" and "usually . . . dispositive" of a term's meaning. Id. at 1315--16 (quoting Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1582 (Fed. Cir. 1996)). Thus, if the specification reveals a "special definition" that differs from the meaning a claim term would otherwise possess, "the inventor's lexicography governs." Id. at 1316. While less useful than the specification for claim construction, the prosecution history may additionally assist in identifying how the inventor perceived the invention and whether the inventor narrowed the scope of the claims at any point. Id. at 1317.

Courts may also rely on evidence which is "external to the patent and prosecution history, including expert and inventor testimony, dictionaries, and learned treatises." Id. at 1317 (quoting Markman, 52 F.3d at 980). Such extrinsic evidence is most reliable when considered in the context of the intrinsic evidence. Id. The Federal Circuit has instructed that courts may consult "general purpose dictionaries" where claims do "not require elaborate interpretation." Id. (quoting Brown v. 3M, 265 F.3d 1349 (Fed. Cir. 2001)).

III. Discussion

The '732 patent relates to a "fire protection sprinkler arrangement" aimed at achieving "improved uniformity of distribution of water for extended coverage." '732 patent at col. 1, ll. 1-2, 64-65; Pl.'s Ex. 1. The patent attains this objective, in part, through the use of a "deflector supported in spaced relation to axial passage" through which water is delivered. Id. at col. 2, ll. 4-10; see also id. at Fig. 1, no. 46; Fig. 3, no. 50. The deflector is described in Claim 1 as "having a central region and a peripheral region surrounding the central region which is bent toward the sprinkler body along a circular bend line[.]" Id. at col. 5, ll. 16-18 (emphasis added).

The parties are only in dispute about one claim term, "bent," as applied the deflector. ...


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