Ridge Corp. v. Kirk NationaLease Co.

Ridge Corp. v. Kirk NationaLease Co. The Federal Circuit held that defendants raised substantial questions of noninfringement under three claim limitations and that plaintiffs had not shown likely irreparable harm. The district court therefore abused its discretion in granting a preliminary injunction. The decision reinforces that, at the preliminary-injunction stage, a substantial claim-construction-based noninfringement question and speculative irreparable-harm evidence will defeat extraordinary relief. Reversed and remanded. Claim 1 required a panel “flexible along the entire length”; the court held defendants raised a substantial question because the accused sandwich panel was rigid except where routed compression gaps allowed it to traverse curved tracks. The “foam insulating material forming the second outermost surface” limitation raised another substantial noninfringement question because the accused door had thermoplastic outer layers with foam in the middle, and prosecution history distinguished similar sandwich structures. The court construed “insulated overhead door” as most reasonably referring to a door with insulating properties suitable for cold-storage applications, while declining to require a particular R-value. Plaintiffs’ price-erosion theory was too speculative and lacked a causal nexus to defendants’ sales; alleged false marking and business-interference conduct also did not support forward-looking relief absent evidence of likely recurrence. Because likelihood of success and irreparable harm were not shown, the preliminary injunction was reversed. claim construction infringement injunction / stay remand precedential claim construction infringement injunction / stay remand precedential claim construction infringement injunction / stay remand