O'Reilly Winship LLC v. SnapRays LLC

O'Reilly Winship LLC v. SnapRays LLC The Federal Circuit held that the district court improperly narrowed the ordinary meaning of "joined" in claim 1 of the '324 patent and that the accused products met that limitation. The court otherwise affirmed summary judgment of non-infringement based on the "configured to," "sandwiched," "three spaced apertures," and other disputed limitations. The decision is a useful reminder that courts cannot narrow an ordinary-meaning construction at summary judgment without intrinsic support, but can still resolve non-infringement where the physical record forecloses the patentee's theory. Reversed-in-part, affirmed-in-part, vacated-in-part, and remanded. The court directed entry of partial summary judgment of infringement for claims 1, 2, and 8 of the '324 patent, remanded for further proceedings on claims 4, 9, and 10 of the '324 patent, and affirmed non-infringement as to the remaining addressed claims. For the '324 patent's "joined" limitation, the claim language did not specify a joining mechanism, and the specification used broad examples of attachment; the district court erred by requiring something more than the accused contact resting in a hole and being held by a rear cover. Because the only disputed limitation for '324 patent claims 1, 2, and 8 was met under the proper construction, the Federal Circuit directed partial summary judgment of infringement on those claims. For the '180 patent's "configured to" limitation, the parties treated the phrase as meaning "designed to"; evidence that the accused spring clips might contact unusually narrow receptacle boxes showed capability, not that they were designed to contact a box wall. The court affirmed the district court's construction and application of "sandwiched" as requiring contact with both insulators, rejecting expert testimony that conflicted with the physical accused products. The court also affirmed non-infringement for the "three spaced apertures" limitation, agreeing that an aperture meant a physical opening, not a translucent covered light area. claim construction infringement remand non-precedential claim construction infringement remand non-precedential claim construction infringement remand non-precedential