TM Patents, L.P. v. IBM Corp.

77 F. Supp. 2d 480, 58 U.S.P.Q. 2d (BNA) 1171, 1999 U.S. Dist. LEXIS 19668
CourtDistrict Court, S.D. New York
DecidedDecember 17, 1999
DocketNo. 97 Civ. 1529 (CM)
StatusPublished

This text of 77 F. Supp. 2d 480 (TM Patents, L.P. v. IBM Corp.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TM Patents, L.P. v. IBM Corp., 77 F. Supp. 2d 480, 58 U.S.P.Q. 2d (BNA) 1171, 1999 U.S. Dist. LEXIS 19668 (S.D.N.Y. 1999).

Opinion

SUPPLEMENTAL MARKMAN RULING

McMAHON, District Judge.

In the Court’s opinion and order dated November 8, 1999, I asked the parties to supplement their initial presentations concerning the meaning of the phrase “one address element” in connection with my [481]*481construction of disputed element iii in Claim 1 of Patent No. 5,212,773 (the ’773 patent), so that I might test my preliminary conclusion that the word “one” encompassed both a single address element and a plurality of address elements. Once again, the parties have provided me with extremely lucid and helpful letters, for which I tender my thanks. It is a pleasure to work on what would otherwise be frighteningly complex issues with lawyers who extend every effort to make them comprehensible.

The meaning of the ubiquitous word “one” continues to trouble me, and I fear that the Federal Circuit’s latest opinion on claim relinquishment, Elkay Mfg. Co. v. Ebco Mfg. Co., 192 F.3d 973, 52 USPQ 2d 1109 (Fed.Cir.1999) — inconveniently decided after our Markman hearing — does not really clarify matters, since it can be read to support both parties’ point of view.

In Elkay, the District Court had construed a claim limitation containing the words “an upstanding feeding tube ... to provide a hygenic flow path for delivering liquid from said inverted unpressurized container ... and for admitting air ... into said container” to encompass both a single tube that performed both functions and two tubes that performed the functions separately. The Federal Circuit reversed. The panel acknowledged (1) that the articles “a” and “an” are not necessarily limited to the singular, and also (2) that the written description, if qualified as a preferred (as opposed to the sole) embodiment, does not conclusively establish that the use of such articles was meant to exclude the plural. However, the appellate court concluded that such a restriction was mandated by the prosecution history of plaintiffs patent.

To understand what the Federal Circuit meant by its ruling, a fairly detailed review of this portion of the opinion is in order. The Court of Appeals started from the proposition that, as a matter of law, the prosecution history “limits the interpretation of claims so as to exclude any interpretation that may have been disclaimed or disavowed during prosecution in order to obtain claim allowance.” El-kay, 52 U.S.P.Q.2d at 1112-13, 1999 WL 715101. It then noted that the Examiner had rejected the original claims corresponding to those in issue based on a prior patent (Krug) in view of yet another prior patent (Savage). The Krug patent described a beer dispensing apparatus with two separate feed tubes, one for pressurized air and one for beer. Savage described an apparatus that allowed a liquid feed tube to be connected to a collapsible bag so that air could not be introduced into the bag as the connection was made. Thus, it seemed clear that the Examiner’s rejection of Elkay’s application was squarely grounded in Elkay’s possible use of multiple tubes. Elkay responded to this rejection by distinguishing Krug on the ground that, inter alia, Elkay claimed “a flow path ... for delivering liquid ... and admitting air” whereas Krug taught the use of separate tubes to perform those two functions. Elkay did not amend the language of its claim, but its argument emphasized the singular nature of the article “a” as used in its application.

The Federal Circuit discounted the fact that Elkay had not filed an amendment to its claim. The court found that the argument Elkay made to overcome the Examiner’s objections was entitled to equal weight as amended language, and that this argument precluded Elkay from contending that its patent covered a device with more than one tube. Moreover, the Federal Circuit ruled that it was “irrelevant whether Elkay emphasized this argument at the time, or indeed whether Elkay had to relinquish an interpretation of the feed tube limitation that could cover more than one flow path for liquid and air.” Id. As long as Elkay made the argument in order to overcome the rejection, it necessarily conceded the point. Finally, the Court noted:

Elkay’s argument that its statement distinguishing Krug on the basis of Krug’s [482]*482use of separate feed tubes was insignificant is particularly unpersuasive in view of the Examiner’s response to that statement. In the Examiner’s Statement of Reasons for Allowance, dated March 30, 1993, the Examiner wrote that he allowed claim 22 (i.e., claim 7 in the ’531 patent) because he understood the claim to describe a single feed tube with a single flow path for both liquid and air: [Examiner’s Statement omitted].

As noted above, both parties find comfort in the Federal Circuit’s reasoning. IBM argues that Elkay stands for a relatively simple and straightforward proposition: once TM amended the claim language, which originally read “at least one message element,” to read “one message element,” it was precluded from taking the position that the word “one” meant “one or more than one.” For a neophyte like myself, there is considerable appeal to this argument. If I could read Elkay to preclude me from relying on anything in the file wrapper except amended language where an amendment is made, I would find that IBM was correct without further analysis.

But the Elkay court carefully stated that “[I]t is the totality of the prosecution history that must be assessed, not the individual segments of the presentation made to the Patent and Trademark Office by the applicant” Id. (emphasis added). There is much in the file wrapper that seems to support TM’s position.

The Examiner originally rejected the claims that eventually became the ’773 patent by Office Action sent June 22, 1991. The Examiner relied on three grounds: first, the claims were indefinite (under 35 U.S.C. § 112(b)); second, certain claims (including independent Claims 2 and 8, which, in their amended version, are in suit here) were anticipated by prior art, namely the Lawrence patent (under 35 U.S.C. § 102); and third, those'claims that were not anticipated were obvious in light of Lawrence. This last objection appears to be directed particularly at Claims 3 and 9 or the original patent application, which are not in suit before me.

In response to the rejection, TM did two things: it amended its claim language in multiple respects (including the substitution of “one” for “at least one” in the claims here in suit), and it submitted an argument to the Examiner. It appears that much of the amended language was designed to overcome the Examiner’s complaint about indefiniteness, which he made as to all the claims. TM’s argument, however,. distinguished Lawrence, and it did so by doing precisely what TM did at the Markman hearing — it contrasted Lawrence’s use of a store-and-forward process with TM’s use of wormhole routing. Unlike the applicant in Elkay, TM did not focus at all on the difference between “at least one” (as used in its original independent claim) and “one” (as used in the amended claim).

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77 F. Supp. 2d 480, 58 U.S.P.Q. 2d (BNA) 1171, 1999 U.S. Dist. LEXIS 19668, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tm-patents-lp-v-ibm-corp-nysd-1999.