Yuntek International, Inc. v. Xiamen JXD Electronic Commerce Co., Ltd.

District Court, N.D. California·Decided June 6, 2022·No. 4:20-cv-07201·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 YUNTEK INTERNATIONAL, INC., Case No. 20-cv-07201-JSW

8 Plaintiff, CLAIMS CONSTRUCTION ORDER v. 9

10 XIAMEN JXD ELECTRONIC COMMERCE CO., LTD., et al., 11 Defendants.

12 13 The Court has been presented with a technology tutorial and briefing leading up to a 14 hearing pursuant to Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996). This Order 15 construes the disputed claim terms selected by the parties, which appear in the patent at issue in 16 this case, United States Patent No. 6,715,446 (“the ’446 Patent”), entitled “Pet Tent.” 17 BACKGROUND 18 The ’446 Patent generally describes a collapsible tent for housing a pet which folds into a 19 storage bag was not in use. (’446 Patent at Abstract.) The design and structure includes a main 20 body as well as front and back panels connected to the body and forming a dome shape. (Id.) 21 The parties dispute the meaning of five claim terms. 22 ANALYSIS 23 A. Legal Standard. 24 Claim construction is a question of law for the Court. Markman, 517 U.S. at 384. “The 25 purpose of claim construction is to determine the meaning and scope of the patent claims asserted 26 to be infringed.” O2 Micro Int’l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351, 1360 (Fed. 27 Cir. 2008). The Court has an obligation “to ensure that questions of the scope of the patent claims 1 (Fed. Cir. 2009) (quotation omitted). Accordingly, the Court must ensure that the parties’ disputes 2 are “fully resolved” and assign “a fixed, unambiguous, legally operative meaning to the claim.” 3 Id. 4 Claim terms are generally given “their ordinary and customary meaning”—i.e., “the 5 meaning that the terms would have to a person of ordinary skill in the art at the time of the 6 invention.” Phillips v. AWH Corp., 415 F.3d 1303, 1312-13 (Fed. Cir. 2005) (en banc). There are 7 only two exceptions to this rule: “1) when a patentee sets out a definition and acts as his own 8 lexicographer, or 2) when the patentee disavows the full scope of a claim term either in the 9 specification or during prosecution.” Thorner v. Sony Computer Entm’t Am. LLC, 669 F.3d 1362, 10 1365 (Fed. Cir. 2012). 11 In determining the ordinary and customary meaning, the claim language “provide[s] 12 substantial guidance as to the meaning of particular claim terms.” Phillips, 415 F.3d at 1314. 13 However, a person of ordinary skill in the art is “deemed to read the claim term not only in the 14 context of the particular claim in which the disputed term appears, but in the context of the entire 15 patent, including the specification.” Id. at 1313. The scope of the claims must always be 16 “determined and confirmed with a full understanding of what the inventors actually invented and 17 intended to envelop with the claim.” Id. at 1316 (quoting Renishaw PLC v. Marposs Soceta’ per 18 Azioni, 158 F.3d 1243, 1250 (Fed. Cir. 1998)). The construction that “stays true to the claim 19 language and most naturally aligns with the patent’s description of the invention” governs. Id. 20 Accordingly, the specification “is always highly relevant to the claim construction analysis” and 21 usually “dispositive.” Id. at 1315. 22 In addition to the claims and the specification, the prosecution history may be used “to 23 provide[] evidence of how the PTO and the inventor understood the patent.” Id. at 1317. “Any 24 explanation, elaboration, or qualification presented by the inventor during patent examination is 25 relevant, for the role of claim construction is to ‘capture the scope of the actual invention’ that is 26 disclosed, described and patented.” Fenner Inv., Ltd. v. Cellco P’ship, 778 F.3d 1320, 1323 (Fed. 27 Cir. 2015). The claims, specification, and prosecution history together constitute the “intrinsic 1 (citation omitted). Courts may also consider extrinsic evidence, such as technical dictionaries and 2 expert testimony, “if the court deems it helpful in determining the ‘true meaning of language used 3 in the patent claims’” and it does not contradict the intrinsic evidence. Id. at 1318 (quoting 4 Markman, 52 F.3d at 980). 5 B. Claim Construction. 6 1. Claim Term: “foldable” 7 Yuntek proposes the construction of the term “foldable” to mean “having structural 8 features that facilitate folding in the manner described.” Defendants propose the construction of 9 the term to have its plain and ordinary meaning. 10 There is a “’heavy presumption’ that a claim term carries its ordinary and customary 11 meaning.” CCS Fitness, Inc. v. Brunswick, Corp., 288 F.3d 1359, 1366 (9th Cir. 2002) (citation 12 omitted). The “ordinary and customary meaning of a claim term is the meaning that the term 13 would have to a person of ordinary skill in the art in question at the time of the invention.” 14 Phillips, 415 F.3d at 1312-13. In addition, the “foldable” requirement in the context of the patent 15 is already modified and defined by restrictions in each asserted claim. See ACTV, Inc. v. Walt 16 Disney Co., 346 F.3d 1082, 1088 (9th Cir. 2003) (holding that the “context of the surrounding 17 words of the claim also must be considered in determining the ordinary and customary meaning of 18 those terms.”). The Court finds that it would be improper to adopt Yuntek’s proposed 19 construction to incorporate additional limitations existent in the various restrictions of the limiting 20 language of the claims. 21 The Court adopts the plain and ordinary meaning of the term and construes “foldable” to 22 mean “able to be folded.” 23 2. Claim Term: “on top of said bottom side [of said main body]” 24 Yuntek proposes the construction of the term “on top of said bottom side [of said main 25 body]” to mean “above and directly adjacent to the bottom side of the main body.” Defendants 26 propose the construction of the term to mean “onto the interior floor of the housing, and on top of 27 any mat or pad on the interior floor of the housing.” 1 removeable from the product should be included in the claim construction. The Court also finds 2 the term “adjacent” in this context to be unnecessarily ambiguous and confusing. 3 The Court construes the term “on top of said bottom side [of said main body]” to mean 4 “directly onto the interior floor of the main body.” 5 3.

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Yuntek International, Inc. v. Xiamen JXD Electronic Commerce Co., Ltd., (N.D. Cal. 2022).

Yuntek International, Inc. v. Xiamen JXD Electronic Commerce Co., Ltd. (Yuntek International, Inc. v. Xiamen JXD Electronic Commerce Co., Ltd.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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