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Novo Industries, L.P. v. Micro Molds Corp., 350 F.3d 1348, 69 U.S.P.Q.2d 1128

Facts

Novo Industries L.P. (Novo) sued Micro Molds Corporation (Micro Molds) for infringing U.S. Patent No. 5,056,578, which pertains to a carrier structure for vertical blind assemblies. The district court found in favor of Novo, concluding that Micro Molds had infringed the patent. However, the court's construction of a specific claim was contested, leading to an appeal by Micro Molds. The appellate court ultimately determined that the district court lacked the authority to correct an error in the patent claim, rendering the claim invalid due to indefiniteness.

Novo is the assignee of the _578 patent, which is directed to a carrier assembly that holds one of a plurality of vertical slats (or blinds) that cover the interior of a window.

Issue

Did the district court have the authority to correct an error in the patent claim, and if not, does this render the claim invalid for indefiniteness?

Did the district court have the authority to correct an error in the patent claim, and if not, does this render the claim invalid for indefiniteness?

Rule

Analysis

The appellate court found that the district court's interpretation of the claim was not appropriate because the intended meaning was subject to reasonable debate. The prosecution history indicated that the claim language had been altered in a way that suggested substantive significance, which further complicated the interpretation. As a result, the appellate court concluded that the claim was invalid for indefiniteness since it could not be clearly understood.

Conclusion

The appellate court reversed the district court's decision, holding that claim 13 of the _578 patent was invalid for indefiniteness.

For the foregoing reasons, we reverse the district court's decision and hold claim 13 of the _578 patent invalid for indefiniteness in its present form.

Who won?

The prevailing party in this case is Micro Molds Corporation, as the appellate court reversed the district court's ruling in favor of Novo Industries L.P. The court found that the district court lacked the authority to correct the patent claim, which led to the conclusion that the claim was invalid due to indefiniteness. This ruling effectively absolved Micro Molds of infringement liability.

The appellate court reversed the district court's decision, holding claim 13 of the _578 patent invalid for indefiniteness in its present form.

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