During Claim Construction, Reading Limitations From A Preferred Embodiment And Importing Limitations Conflicting With A Preferred Embodiment Are Improper

In GE Lighting Solutions, LLC v. AgiLight, Inc., No. 13-1267 (Fed. Cir. May 1, 2014), the Federal Circuit affirmed-in-part and reversed-in-part the district court's claim construction and associated SJ of noninfringement.

GE Lighting Solutions, LLC ("GE") sued AgiLight, Inc. ("AgiLight") for infringement of U.S. Patent Nos. 7,160,140 ("the '140 patent"); 7,520,771 ("the '771 patent"); 7,832,896 ("the '896 patent"); and 7,633,055 ("the '055 patent"). The '140 and '771 patents are directed to light-emitting diode ("LED") string lights that include an LED, an insulated electrical conductor (e.g., a wire), and an insulation displacement connector ("IDC connector"). The '896 patent is directed to an optical element that houses an LED and interacts with the light emitted therefrom to increase its viewing angle. The '055 patent is directed to an overmolding process that applies a protective sealant over the printed circuit board ("PCB") to which an LED is attached.

The district court construed three claim terms. For the '140 and '771 patents, the district court construed the term "IDC connector" in the claims as requiring certain specialized features, despite recognizing that "IDC connector" is commonly used in electrical engineering to connote a range of devices. The district court relied on a disclosed embodiment and limitations of several dependent claims in making this determination. For the '896 patent, the district court construed the claim term, "[an] optical element having a substantially ellipsoidal inner profile and generally spherical outer profile," as requiring the entire inner profile of the optical element to be substantially ellipsoidal, with an outer three-dimensional surface where the points on the surface are generally equidistant from a center point. For the '055 patent, the district court construed the claim term "annular gasket" to be "a three-dimensional deformable material used to make a pressure-tight joint between stationary parts, with an opening in its center capable of sealing off its center area when bonded statically between stationary parts on its top and bottom. Slip op. at 14 (citation omitted). Based on the construction of these claim terms, the district court granted AgiLight's motion for SJ of noninfringement for all four patents. GE appealed.

"[T]he specification and prosecution history only compel departure from the plain meaning in two instances: lexicography and disavowal." Slip op. at 5 (citing Thorner v...