The Federal Circuit affirmed the district court’s grant of summary judgment of non-infringement. The patent-at-issue involved the external appearance of a pickup truck having built-in storage. The claims required a hinged portion that is constructed such that the truck has an external appearance of a conventional pickup truck, which the court construed to mean “the hinged portion is constructed such that the storage box is not obvious from the outward appearance of the pickup.” The Federal Circuit affirmed this construction over Clare’s arguments that the limitations do not need construction. The parties disputed the meaning, even though readily understandable to a lay person, and therefore construction was necessary. Having construed the claims, the court held that no reasonable jury could have found that the accused pickup trucks meet the limitations of the claims, as their storage compartments were obvious from the outward appearance of the pickup.
Scott Clare v. Chrysler Group LLC, Case No. 2015-1199 (March 31, 2016); Opinion by: Moore, joined by Prost and Wallach; Appealed From: United States District Court for the Eastern District of Michigan, Edmunds, J. Read the full opinion here.