Phillips v. AWH Corp. (Fed. Cir. 2004)
In a case involving modular wall panels for prisons (U.S. Patent 4,677,798), the Federal Circuit interpreted the term “baffles” to structures oriented at angles other than 90 degrees. Although the ordinary meaning of the term (“something for deflecting, checking, or otherwise regulating flow”) includes 90 degree orientations, the Court listed two reasons for abandoning the ordinary meaning. First, the only embodiment shows “baffles angled at other than 90 degrees.” Next, the Court found that baffles angled at other than 90 degrees better realize the invention’s purpose of providing impact or projectile resistance.
In dissent, Judge Dyk argued that 1) a patent describing only a single embodiment is limited to that embodiment, and 2) impact or projectile resistance was not the only objective listed in the patent and claims are not required to be capable of achieving all of the objectives of an invention.
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NOTE: This case is scheduled for a rehearing en banc and will likely create dramatic changes to patent litigation procedures, just as Markman has done. Read more here.