Judges should start with the inventor's description. A dictionary gives you all possible meanings of a word, but the inventor's own description tells you what the word meant for their specific invention. In this case, even though the inventor only showed angled baffles, he never said that was the *only* kind of baffle his invention used. Therefore, the patent could also cover baffles at a normal 90-degree angle, and the case should continue to see if AWH copied the invention.

I agree that we should focus on the inventor's description. But if you actually read this inventor's description, he talks about angled baffles over and over again. Every drawing shows angled baffles. He clearly meant for 'baffles' to be angled. The first judge got it right, and we should have just agreed with his decision that AWH did not copy the invention.

This whole argument is a waste of time. Our appeals court's method for handling these cases is broken. We pretend it's a simple legal question, but it's really about understanding complex facts. We should trust the first judge who heard all the evidence instead of re-deciding everything from scratch. Our current system just creates confusion and isn't fair.

Yes, the word 'baffles' in the patent doesn't only mean slanted parts. The patent's description shows that 'baffles' can do different things, not just block bullets. So the earlier decision was wrong and needs to be looked at again. The patent's own words and description are the most important things to look at when figuring out what it means.

No, the word 'baffles' should only mean slanted parts based on how the invention is described in the patent. The court's original decision should stay the same. The right meaning is the one that matches best with the patent's description.

Agrees with using the patent description to understand the meaning of words in the claims. Disagrees with sending the case back to the lower court, because the patent clearly describes the baffles as slanted to block bullets and never mentions straight baffles, so the original decision was correct.

"[T] he words of a claim are generally given their ordinary and customary meaning....[Which is] the meaning that the term would have to a person of ordinary skill in the art in question at the time of the invention, ie, as of the effective filing date of the patent application."

The court may also consider extrinsic evidence, such as dictionaries, treatises, and expert testimony, but such evidence "is less significant than the intrinsic record in determining `the legally operative meaning of claim language'"and" is unlikely to result in a reliable interpretation of patent scope unless considered in the context of the intrinsic evidence. "

"It is a `bedrock principle'of patent law that `the claims of a patent define the invention to which the patentee is entitled the right to exclude.'"

In some cases, the ordinary meaning of claim language as understood by a person of skill in the art may be readily apparent even to lay judges, and claim construction in such cases involves little more than the application of the widely accepted meaning of commonly understood words

"[T] he claims themselves provide substantial guidance as to the meaning of particular claim terms."

"[T] he specification `is always highly relevant to the claim construction analysis. Usually, it is dispositive; it is the single best guide to the meaning of a disputed term.'"

The intrinsic evidence includes the claims themselves, the specification, and the prosecution history.

T] he specification may reveal a special definition given to a claim term by the patentee that differs from the meaning it would otherwise possess. In such cases, the inventor's lexicography governs

"The construction that stays true to the claim language and most naturally aligns with the patent's description of the invention will be... the correct construction."

No, a court should not primarily rely on dictionary definitions. The patent's specification and prosecution history are the primary guides to a claim term's meaning. The court rejects the dictionary-first methodology of Texas Digital, holding that the 'ordinary meaning' of a claim term is its meaning to an ordinary artisan after reading the entire patent. The specification is the 'single best guide' because it provides the context in which the inventor used the term. While dictionaries can be useful, overreliance on them risks adopting a meaning divorced from the invention itself. Applying this principle, the court found that the term 'baffles' was not limited to the angled embodiments shown in the specification, partly because dependent claims added that specific limitation, implying the independent claim was broader. Therefore, the district court's narrow construction was incorrect.

No. The author agrees with the majority's new framework prioritizing the specification over dictionaries. However, he dissents from the majority's application of that framework to the facts of this case. He argues that the specification overwhelmingly and consistently describes the invention's baffles as being angled for the purpose of deflecting projectiles, with every diagram and description supporting this narrower meaning. Therefore, a proper reading of the specification—the 'single best guide'—should lead to the conclusion that 'baffles' are limited to angled structures, and the district court's judgment of noninfringement should have been affirmed.

This opinion does not directly answer the issue, instead arguing that the entire framework for appellate review of claim construction is flawed. The dissent contends that claim construction is not a pure question of law but involves underlying factual determinations, such as defining the person of ordinary skill in the art and the state of the art at the time of invention. Therefore, the appellate court should review the trial court's findings with deference under a 'clearly erroneous' standard, not conduct a de novo review. The court's persistence in treating claim construction as a pure legal question is a 'futility' that creates uncertainty and undermines the judicial process.

Yes. The term 'baffles' does not require a restrictive definition limited to structures that are angled to deflect projectiles. The specification of the '798 patent does not limit the term 'baffles' to such a restrictive definition, and the claims and specification indicate that baffles serve multiple purposes, including load-bearing and obstructing flow. The district court's summary judgment of noninfringement is reversed, and the case is remanded for further proceedings. The intrinsic evidence, including the claims, specification, and prosecution history, guides the interpretation of patent scope, and the specification is the single best guide to the meaning of a disputed term.

No. The term 'baffles' should be given a restrictive definition based on the specification's description of the invention. The district court's decision should be affirmed. The construction that stays true to the claim language and most naturally aligns with the patent's description of the invention will be the correct construction.

Concurs with the majority's resolution of the 'specification v. dictionaries' issue in favor of relying on the specification. Dissents from the decision to reverse and remand, arguing that the district court's decision should be affirmed because the specification clearly describes the baffles as being angled to deflect bullets and contains no disclosure of baffles at right angles.

Phillips v. AWH Corporation

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Issue:

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Majority, Concurrences & Dissents

Analysis:

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