Multiquip Inc v. ANA Inc

CourtDistrict Court, N.D. Texas
DecidedNovember 22, 2023
Docket3:22-cv-02599
StatusUnknown

This text of Multiquip Inc v. ANA Inc (Multiquip Inc v. ANA Inc) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Multiquip Inc v. ANA Inc, (N.D. Tex. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

MULTIQUIP INC., § § Plaintiff, § § v. § Civil Action No. 3:22-cv-02599-M § ANA, INC., § § Defendant. § §

CLAIM CONSTRUCTION MEMORANDUM OPINION AND ORDER

This Order addresses the claim construction disputes presented by Plaintiff Multiquip Inc. (“Multiquip”) and Defendant ANA, Inc. (“ANA”) as to U.S. Patent No. 8,816,651 (the “’651 patent”). On October 23, 2023, the Court held a claim construction hearing. Having considered the arguments and evidence presented by the parties at the claim construction hearing, the Court issues this Order addressing claim construction disputes as to the ’651 patent. I. BACKGROUND Multiquip asserts that ANA infringes certain claims of the ’651 patent. First. Am. Compl. (ECF No. 29) ¶ 53. ANA asserts counterclaims seeking a declaratory judgment of non- infringement and invalidity of the ’651 patent. Answer to First Am. Compl. and Amended Counterclaims (ECF No. 30) ¶¶ 145–53. The ’651 patent recites an “Engine-generator with load bank and control system.” The specification explains that electric generators often operate under variable demand, i.e., load, conditions. See generally ’651 patent at 1:11–2:18. Light-load conditions can create problems such as unburned fuel and, in turn, the increased formation of carbon deposits and tar—referred to as “wet stacking”—and soot that can affect engine operability. It was known in the prior art that wet stacking could be mitigated by connecting the generator to a “dummy” load, consisting of banks of resistors that may be switched in steps, in parallel to the actual load, such that the engine always experiences a minimum demand. In addition, prior art engines are often equipped

with “regeneration” features to burn-off soot that can accumulate on particulate filters, which operate more efficiently under high-load conditions. The ’651 patent explains that prior art dummy load systems tend to be wasteful by requiring a set amount of fuel to be burned at all times, resulting in more consumption of fuel than is perhaps necessary. In addition, prior art load banks have not previously been employed to assist with regeneration. The ’651 patent purports to address these problems in the prior art by disclosing “a load bank that provides a dummy load to an electric generator, which allows an engine-generator unit to more efficiently operate by decreasing the frequency of regeneration cycles an engine must initiate, and, when regeneration occurs, ensures a minimum generator load to raise exhaust temperatures and thus increase regeneration efficiency.” Id. at 2:22–28.

Claim 1 of the ’651 patent recites: An engine-generator and load bank system comprising: an engine mechanically connected to and capable of driving an alternator; said engine having an engine control module and a particulate filter; said alternator in electrical communication with an output bus and a load bank bus; at least one load monitoring device in electrical communication with said output and load bank buses; a generator controller comprising a load dump output and a load enable output, said generator controller in electrical communication with said engine control module; a load bank controller comprising a load enable input, a load dump input, a load sensor, and at least one load step output; said load dump output in electrical communication with said load dump input; said load enable output in electrical communication with said load enable input; said load monitoring device in electrical communication with said load sensor; at least one load step contactor in electrical communication with said at least one load step output; and at least one load step resistor in electrical communication with said load bank bus by way of said at least one load step contactor; wherein said generator controller provides a control signal via said load enable output in at least one of the following cases: neglect and regeneration; and wherein said generator controller provides a control signal via said load dump output in case of a load spike. Id. cl. 1 (emphasis added). Claim 19 of the ’651 patent recites: An engine-generator and load bank system comprising: an engine mechanically connected to and capable of driving an alternator; said engine having an engine control module and a particulate filter; said alternator in electrical communication with an output bus and a load bank bus; a generator controller in electrical communication with said engine control module, said generator controller having at least one load step output; at least one load step contactor in electrical communication with said at least one load step output; and at least one load step resistor in electrical communication with said load bank bus by way of said at least one load step contactor; wherein said generator controller is capable of operating said load step contactor to connect said load step resistor in at least one of the following cases: neglect and regeneration; and wherein said generator controller is capable of operating said load step contactor to disconnect said load step resistor in case of a load spike. Id. cl. 19 (emphasis added). II. LEGAL STANDARD A. General Principles of Claim Construction The construction of disputed claims is a question of law for the court. Markman v. Westview Instruments, Inc., 52 F.3d 967, 971–72 (Fed. Cir. 1995), aff’d, 517 U.S. 370 (1996). “Ultimately, the interpretation to be given a term can only be determined and confirmed with a full understanding of what the inventors actually invented and intended to envelop with the claim.” Phillips v. AWH Corp., 415 F.3d 1303, 1316 (Fed. Cir. 2005) (en banc) (citation omitted). Accordingly, a proper construction “stays true to the claim language and most naturally aligns with the patent’s description of the invention.” Id. (citation omitted). “It is a ‘bedrock principle’ of patent law that ‘the claims of a patent define the invention

to which the patentee is entitled the right to exclude.’” Phillips, 415 F.3d at 1312 (quoting Innova/Pure Water, Inc. v. Safari Water Filtration Sys., Inc., 381 F.3d 1111, 1115 (Fed. Cir. 2004)). Courts first “look to the words of the claims themselves . . . to define the scope of the patented invention.” Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1582 (Fed. Cir. 1996) (citation omitted). The claim terms are “generally given their ordinary and customary meaning,” but “a patentee may choose to be his own lexicographer and use terms in a manner other than their ordinary meaning, as long as the special definition of the term is clearly stated in the patent specification or file history.” Id. (citation omitted). The “ordinary and customary meaning” of the terms in a claim is “the meaning that the term[s] would have to a person of ordinary skill in

the art in question at the time of the invention.” Phillips, 415 F.3d at 1313. When the meaning of a term to a person of ordinary skill in the art is not apparent, a court is required to consult other sources, including “the words of the claims themselves, the remainder of the specification, the prosecution history, extrinsic evidence concerning relevant scientific principles, the meaning of technical terms, and the state of the art.” Id. (citation omitted). A

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Multiquip Inc v. ANA Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/multiquip-inc-v-ana-inc-txnd-2023.