American Seating Co. v. USSC Group, Inc.

91 F. App'x 669
CourtCourt of Appeals for the Federal Circuit
DecidedFebruary 26, 2004
DocketNo. 03-1429
StatusPublished
Cited by2 cases

This text of 91 F. App'x 669 (American Seating Co. v. USSC Group, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Federal Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Seating Co. v. USSC Group, Inc., 91 F. App'x 669 (Fed. Cir. 2004).

Opinion

BRYSON, Circuit Judge.

American Seating Corporation makes products for use in mass transit vehicles, including a wheelchair restraint system and a vandal-resistant bus seat. American Seating has patents covering both products, one that covers the wheelchair restraint system and two that cover the van[671]*671dal-resistant seating insert. The USSC Group also manufactures wheelchair restraint systems and vandal-resistant seats. Believing that the USSC Group was infringing its patents, American Seating filed suit in the United States District Court for the Western District of Michigan.

American Seating alleged that its patent on the wheelchair restraint system was infringed by two of the USSC Group’s products: the VPRo I and the VPRo II. American Seating also alleged that its patents on the vandal-resistant seating insert were infringed by the “T2C” product sold by the USSC Group. The district court granted summary judgment of noninfringement as to all three patents. American Seating Co. v. USSC Group, Inc., No. 1:01-CV578 (W.D.Mich. Jan. 30, 2003). We affirm in part, reverse in part, and remand.

I

The first patent, U.S. Patent No. 5,888,-038 (“the ’038 patent”), covers a system for securing wheelchairs in mass transit vehicles. The means for securing the wheelchair in the vehicle consists of two parts: (1) a means for engaging a portion of the wheelchair under tension; and (2) a movable securing element (a movable arm) with a housing mounted on it that receives one end of a flexible and adjustable strap. To secure the wheelchair in place, an operator deploys straps that are fastened to the vehicle (the “means for engaging a portion of [the] wheelchair”) and attaches the straps to the body of the wheelchair. The operator then swings the movable arm from its storage position into an operating position and locks the movable arm into place. Once the arm is in the operating position, the operator attaches the straps that are housed on the movable arm to the wheelchair under tension so that the two sets of straps cooperate to hold the wheelchair in place. Claim 1 of the ’038 patent claims the system as follows:

1. In combination,

(a) a vehicle having an area for receiving a wheelchair, and
(b) means for securing a wheelchair in said area to said vehicle, wherein said means for securing is permanently attached to said vehicle and comprises:
(i) means for engaging a portion of said wheelchair under tension, said means for engaging being locked to said vehicle at a predetermined location, and
(ii) a movable securing element having mounted thereon a housing and flexible strap, said flexible strap having one end adjust-ably received in said housing and an opposite end adapted to engage a portion of said wheelchair in said area under tension, said movable securing element being movable with respect to said vehicle between an operating position wherein said housing is locked to said vehicle at a further location for cooperation with said means for engaging to secure said wheelchair and a storage position wherein said housing is remote from said further location.

The district court construed subsection (b)(i) of the claim to require that the “means for engaging a portion of said wheelchair” be locked directly to the vehicle, rather than to a structure within the vehicle such as a sidewall or bulkhead. The court construed subsection (b)(ii) of the claim to require that the movable securing element containing the housing be locked directly to the floor of the vehicle when in the operating position. The court [672]*672construed the term “locked” to mean “made immobile with respect to the vehicle by use of a mechanical means, the means engaging the vehicle in some manner, which means can be disengaged by mechanical force applied by an operator or user.”

Based on its claim construction, the district court granted summary judgment of noninfringement as to both the VPRo I and the VPRo II. The court held that the VPRo I did not infringe because the locking mechanism on the VPRo I “does not directly interface with the vehicle” but instead “interfaces with a sidewall or bulkhead.” The court held that the VPRo II did not infringe for two reasons: (1) because the VPRo II employed, “at least in part, a friction lock through the use of the wheelchair restraint belts,” rather than a mechanical lock; and (2) because the locking mechanism for the movable securing element did not interact directly “with the vehicle.”

A

With respect to the VPRo I, American Seating argues that the trial court improperly required that the “means for engaging a portion of said wheelchair” set forth in subsection (b)(i) of claim 1 directly interface with the vehicle, and not with a bulkhead or sidewall of the vehicle. We agree with American Seating that the court’s interpretation of the claim was incorrect. The claim requires only that the means for securing the wheelchair be “permanently attached to said vehicle at a predetermined location” and that the means for engaging be locked “to said vehicle.” Nothing in the claim or the specification suggests that the securing and engaging means must be attached to the floor or chassis of the vehicle. To the contrary, the reference to the “vehicle” would seem to include any structure that is a permanently part or permanently affixed to the vehicle, such as a bracket, sidewall, or bulkhead. In fact, in the preferred embodiment the adjustable straps that attach to the rear of the wheelchair are attached to what the patent refers to as the “fixed securing element,” which is depicted in the patent figures as a bulkhead rising from the floor of the vehicle. Thus, even in the preferred embodiment, the straps and hooks that constitute the “means for engaging a portion of said wheelchair” are attached to a structure other than the vehicle floor. We therefore reject the district court’s construction of the claim as requiring that the “means for engaging” the wheelchair be locked to a portion of the vehicle other than a sidewall or bulkhead. Because there was evidence in the summary judgment proceeding that the “means for engaging” the wheelchair in the VPRo I is attached to structures that are permanently attached to the vehicle, the court’s summary judgment of noninfringement cannot be sustained on this ground.

In support of its argument that the VPRo I does not infringe claim 1 of the ’038 patent, the USSC Group argues that the claim language requires “that there be a disengageable type lock between the movable securing element and the vehicle without any intermediate parts.” That argument differs from the ground on which the district court held that the VPRo I did not infringe. The district court rested its ruling with respect to the VPRo I on the “means for engaging” limitation (limitation (b)(i) of claim 1) rather than the “movable securing element” limitation (limitation (b)(ii) of claim 1), to which much of the USSC Group’s argument is directed. In any event, however, the USSC Group’s argument with respect to the VPRo I is unavailing.

[673]*673The USSC Group argues that the claim language providing that the housing must be “locked to said vehicle at a further location” requires that the movable arm and housing must “engage the vehicle at a location separate from where the arm is attached to the vehicle at its pivot point.” We find no support for that argument in either the claim language or the specification.

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Bluebook (online)
91 F. App'x 669, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-seating-co-v-ussc-group-inc-cafc-2004.