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appealpatent

patent

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Laitram Corp. v. Rexnord, Inc., 939 F.2d 1533, 19 U.S.P.Q.2d 1367

Facts

Laitram Corp. brought a patent infringement action against Rexnord, claiming that Rexnord's 4707 conveyor product infringed claims 21 and 22 of U.S. Patent No. 4,051,949. The district court found in favor of Laitram, ruling that Rexnord's product infringed the patent. However, Rexnord appealed, arguing that the district court erred in its interpretation of the patent claims and that its product did not infringe. The case revolves around the interpretation of a means-plus-function claim related to a conveyor belt design.

The invention claimed in the '949 patent is directed to a conveyor belt which addresses the problem of tippage of containers being conveyed.

Issue

Did the district court err in its interpretation of the patent claims, and did Rexnord's 4707 conveyor product infringe on Laitram's patent?

Rule

To establish infringement, every limitation set forth in a patent claim must be found in an accused product or process exactly or by a substantial equivalent. Corning Glass Works v. Sumitomo Elec. U.S.A., Inc., 868 F.2d 1251, 1259, 9 USPQ2d 1962, 1967 (Fed.Cir.1989). The patentee bears the burden of proving infringement by a preponderance of the evidence. Amstar Corp. v. Envirotech Corp., 823 F.2d 1538, 1545, 3 USPQ2d 1412, 1417 (Fed.Cir.1987).

Analysis

Conclusion

The Court of Appeals reversed the district court's finding of infringement, concluding that Laitram failed to prove that Rexnord's product met the necessary claim limitations.

For the foregoing reasons, we reverse the judgment of infringement.

Who won?

Rexnord prevailed in the appeal, as the Court of Appeals reversed the district court's ruling of infringement. The appellate court found that the district court had misinterpreted the patent claims, particularly regarding the means-plus-function language. The court determined that the accused device did not have the structural equivalence required to meet the patent's claim limitations, thus ruling in favor of Rexnord.

Costs to Rexnord.

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