Woodway USA, Inc. v. LifeCORE Fitness, Inc.

Woodway USA, Inc. v. LifeCORE Fitness, Inc. The Federal Circuit held that the district court adopted an overly restrictive construction of "substantially prevent" by effectively requiring complete prevention of movement in the dispreferred direction. The prosecution history did not clearly and unmistakably disclaim all bidirectional belt movement. The decision reinforces that prosecution statements distinguishing prior art must be read in context and must be clear and unmistakable before narrowing an approximating claim term like "substantially." Vacated the summary judgment of noninfringement and remanded for further proceedings under the correct claim construction; costs awarded to Woodway. The asserted patents cover manual treadmills with curved running surfaces and safety features intended to allow belt movement in a preferred direction while "substantially preventing" movement in the opposite direction. The district court construed "substantially prevent" to mean restricting rotation to allow only one rotational direction, then granted summary judgment because the accused belts could rotate bidirectionally. The Federal Circuit held that the plain meaning of "substantially" allows approximation—e.g., largely but not necessarily entirely—and that the specification did not require total prevention of reverse movement. Prosecution arguments distinguishing Bostic and Savettiere did not amount to clear and unmistakable disclaimer; they could reasonably be read as distinguishing references whose safety mechanisms did not restrict treadmill-belt movement in the claimed way. Because the noninfringement judgment depended on the erroneous construction, the court vacated and remanded without deciding whether the accused products infringe under the correct construction. claim construction infringement remand non-precedential claim construction infringement remand non-precedential claim construction infringement remand