Teashot.LLC v. Green Mountain Coffee Roasters, Inc.
595 F. App'x 983 (2015)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A product with a non-permeable surface that is punctured to allow fluid to pass through a resulting hole does not literally infringe a patent claim requiring a body 'constructed of a water-permeable material,' as the material itself is not permeable.
Facts:
- Teashot.LLC owns U.S. Patent No. 5,895,672, which describes a 'tea extraction system' for use in coffee brewing machines.
- Claim 1 of the patent requires a 'tea extraction container' with a 'sealed body' that is 'constructed of a water-permeable material'.
- The patent specifies this material must allow 'flow of a fluid through said sealed body to produce a tea extract'.
- Green Mountain Coffee Roasters, Inc., Keurig, Inc., and Starbucks Corp. (collectively, 'Green Mountain') manufacture and sell tea-brewing K-Cups.
- The accused K-Cups have a solid foil lid that is not permeable to water.
- During use, a needle in the brewing machine punctures the foil lid, creating a hole through which hot water is injected into the K-Cup.
Procedural Posture:
- Teashot.LLC sued Green Mountain Coffee Roasters, Inc., Keurig, Inc., and Starbucks Corp. in the U.S. District Court for the District of Colorado for patent infringement.
- The district court construed the disputed claim term 'sealed body is constructed of a water-permeable material.'
- The district court found that Teashot had waived its right to argue infringement under the doctrine of equivalents by failing to timely disclose the theory.
- Green Mountain moved for summary judgment of non-infringement.
- The district court granted summary judgment in favor of Green Mountain.
- Teashot (as appellant) appealed the district court's claim construction and the summary judgment ruling to the U.S. Court of Appeals for the Federal Circuit, where Green Mountain was the appellee.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a tea pod with a foil lid that is punctured by a brewing device to allow water to enter literally infringe a patent claim requiring a 'sealed body' that is 'constructed of a water-permeable material which allows flow of a fluid through said sealed body'?
Opinions:
Majority - Chief Judge Prost
No. A tea pod with a puncturable foil lid does not literally infringe a patent claim requiring construction from a 'water-permeable material.' The court first addressed claim construction, holding that the phrase 'water-permeable material' means the material itself must allow fluid to pass through it, based on the plain language of the claim and the consistent descriptions in the patent's specification. The court rejected Teashot's argument that Figure 4 of the patent disclosed an alternative, finding the figure was silent on the means of fluid entry and could not contradict the patent's otherwise consistent teaching. Applying this construction, the court found no literal infringement because Green Mountain's K-Cup lid is made of foil, which is not water-permeable. Water flows through a hole punctured in the foil, not through the foil material itself, a fact Teashot's own inventor admitted. The court also affirmed the district court's decision to exclude Teashot's doctrine of equivalents theory, finding Teashot had waived the argument by failing to disclose it in a timely manner as required by the court's scheduling order.
Analysis:
This decision reinforces the principle that claim terms are interpreted based on their plain meaning within the context of the patent's specification. It establishes a clear distinction between a material that is inherently permeable and a non-permeable material that is mechanically altered (punctured) to permit fluid flow. The ruling limits the scope of claims to what is explicitly described and enabled, preventing patentees from extending protection to technologies that achieve a similar result through a different mechanism not contemplated in the patent. The case also serves as a strong procedural warning to litigants about the consequences of failing to timely disclose all theories of infringement, as such failures can result in a waiver of the right to argue those theories.
Unlock the full brief for Teashot.LLC v. Green Mountain Coffee Roasters, Inc.