SRAM v. AD-II (Fed. Cir. 2006).
SRAM cases are always great because they involve interesting mechanical technology. This one involves a shift actuator for a bicycle derailleur. After claim construction, the district court granted summary judgment for SRAM and issued a permanent injunction against AD-II.
On appeal, AD-II argued that the lower court was too narrow in its construction, and that a proper broad construction of the claims would render them invalid. The CAFC agreed. Of note, during prosecution (and three reexamination proceedings) the PTO examiner construed the disputed term in the same fashion followed by the district court. (Not always explicitly). On appeal, the CAFC gave those interpretations no consideration.
[P]aradoxically in this case, the PTO construed the claim narrowly, rather than broadly, by reading in the same limitation as did the district court. In doing so, the PTO erred for the same reasons as did the district court. The Patent Examiner’s actions thus provide no support for SRAM’s argument. Furthermore, this court is not bound by the PTO’s claim interpretation because we review claim construction de novo.
Vacated and remanded.
Notes:
- Although claim construction is de novo this decision appears to rub against notions of prosecution-based-interpretation found in other cases
- For more information on bicycle patents and innovation, check out Patent Attorney Bob Shaver’s Patent Pending Blog.
