Means-Plus-Function Element Limited To Single Disclosed Structure And Equivalents Thereof

Judges: Bryson, Moore (author), Reyna [Appealed from E.D. Tex., Magistrate Judge Giblin]

In Mettler-Toledo, Inc. v. B-Tek Scales, LLC, Nos. 11-1173, -1200 (Fed. Cir. Feb. 8, 2012), the Federal Circuit affirmed the district court's denial of JMOL after jury verdicts that one of the two patents-in-suit was not infringed and that the other patent-in-suit was not infringed and was invalid. The Court also affirmed the district court's denial of sanctions against Mettler-Toledo, Inc. ("Mettler") for allegedly withholding and destroying relevant documents.

Mettler owns U.S. Patent Nos. 4,815,547 ("the '547 patent") and 4,804,052 ("the '052 patent"), which are directed to technology used to weigh objects such as large commercial trucks. The '547 patent describes an individual load cell that is one of several cells used in a scale. The cell produces an electrical signal when deformed, for example, by an object to be weighed. The '052 patent is directed to a system and method for weighing objects on a scale, which includes a correction based on the location of the object on the scale. That system of the '052 patent ensures that the measured weight is the same regardless of where on the scale the object is placed.

After Mettler sued B-Tek Scales, LLC ("B-Tek") for infringing certain claims of the '547 and '052 patents, a jury found that B-Tek did not infringe any of the asserted claims. The jury also determined that the asserted claims of the '052 patent would have been obvious. Mettler moved for JMOL on both the infringement and invalidity issues, which the district court denied. B-Tek moved for sanctions after trial, alleging that Mettler had concealed certain documents, and the district court denied B-Tek's motion. Mettler appealed the district court's denial of its motion for JMOL for both patents. B-Tek cross-appealed the denial of sanctions.

On appeal, the Federal Circuit applied Fifth Circuit law in reviewing the denials of JMOL. In the Fifth Circuit, JMOL is appropriate if the facts and inferences point so strongly and overwhelmingly in favor of one party that a reasonable jury could not have concluded otherwise. First considering denial of Mettler's motion for JMOL with regard to the '547 patent, the Court found claim 1 of the '547 patent illustrative of the asserted claims. Claim 1 is directed to a weighing apparatus comprising a counterforce and various means-plus-function elements associated with an electronic circuit. The circuit, as...