Background
SnapRays LLC, doing business as SnapPower, owns U.S. Patent Nos. 9,871,324 and 9,035,180, which concern powered electrical cover plates capable of supplying features such as night lighting. Its competitor O’Reilly Winship LLC, doing business as OWL, began selling BriteOWL lighted cover plates in 2019.
After SnapPower sent demand letters and submitted infringement notifications concerning OWL’s Amazon listings, OWL sued in the Northern District of Texas for declarations of noninfringement. SnapPower counterclaimed for infringement. Following claim construction, the district court granted OWL summary judgment of noninfringement on all asserted claims and denied SnapPower’s motion for partial summary judgment of infringement.
The Court’s Holding
The Federal Circuit held that the district court construed “joined” in claim 1 of the ’324 patent too narrowly. The claim did not require an unidentified degree or method of mechanical fastening beyond the contact being held together with the resilient strip. Because OWL’s contact rested in the strip’s hole and was held there by an attached rear cover, the accused products met the limitation. The court reversed noninfringement as to claims 1, 2, 4, 8, 9, and 10, and directed the district court to grant SnapPower partial summary judgment of infringement on claims 1, 2, and 8. It remanded claims 4, 9, and 10 for further proceedings.
The court upheld noninfringement on the remaining claims. OWL’s spring clips were not “configured to” contact receptacle-box walls merely because they might touch unusually narrow boxes; the evidence showed they did not touch most boxes and could be damaged in a narrow one. The court also upheld constructions requiring some direct contact for a conductor “sandwiched” between insulators and treating an “aperture” as a physical opening. It further rejected SnapPower’s challenge concerning where the ’180 patent’s flexible conductive portion was connected. The judgment was therefore reversed in part, affirmed in part, vacated in part, and remanded.
Key Takeaways
- A court may not narrow an ordinary claim term such as “joined” without support in the claim language, specification, or prosecution history.
- The undisputed structure of OWL’s products established infringement of claims 1, 2, and 8 of the ’324 patent as a matter of law.
- Mere capability of contacting an unusually narrow receptacle box did not show that a spring clip was “designed to,” and therefore “configured to,” contact the box wall.
Why It Matters
The nonprecedential decision illustrates that an unstated structural requirement imposed during summary judgment can amount to an erroneous claim construction. It also shows the limits of capability evidence when the parties have agreed that “configured to” means “designed to.”
On remand, SnapPower is entitled to an infringement judgment on three ’324 patent claims and further proceedings on three others, while OWL retains noninfringement judgments covering the balance of the asserted claims addressed on appeal.