On appeal, the Federal Circuit reversed four claim constructions provided by the district court. First, the court held that the district court erred by construing a part of the preamble that described the purpose of the claimed method and was unnecessary for antecedent basis or to breathe life into the claim, even where another part of the preamble was construed because it did provide antecedent basis. Next, the district court erred by limiting a claim term such that it “does not contain” maps, when the correct construction would have required only that it “does not require” maps. The prosecution history did not support the court’s limitation. As to the term “node,” the district court’s construction was too narrow; there was neither lexicography nor disavowal in this case. Lastly, the district court’s construction for “storage device” was incorrect, because the term should be given its plain and ordinary meaning, i.e., “storage device” means “storage device.”
TomTom, Inc. v. Adolph, Case No. 2014-1699 (June 19, 2015); Opinion by: Wallach, joined by Hughes and Fogel, by designation; Appealed From: District Court for the Eastern District of Virginia, Ellis, J. Read the full opinion here.
