Narrative Opinion Summary
The case involves MeadWestvaco Corporation and MeadWestvaco Calmar, Inc. (plaintiffs-appellees) appealing a district court decision against Rexam Beauty and Closures, Inc. and Valois entities (defendants-appellants) concerning patent infringement and validity for U.S. Patent Nos. 7,718,132 and 7,722,819. The core legal issues include the interpretation of patent claims, nonobviousness, and indefiniteness, with procedural history involving summary judgments and expert testimony. The Federal Circuit vacated the district court's summary judgment on nonobviousness due to unresolved material factual disputes, but it affirmed the claim constructions and the admissibility of expert testimony. The court found that Rexam and Valois waived their indefiniteness arguments by not addressing them at trial. In terms of patent infringement, the court upheld that the defendants infringed on the generic dispenser claims of the '132 patent. Consequently, the decision was affirmed in part, vacated in part, and remanded for further proceedings.
Legal Issues Addressed
Claim Constructionsubscribe to see similar legal issues
Application: The court affirmed the district court's interpretation of patent terms, including 'quenched' and 'transparency,' supporting broader definitions that align with ordinary meanings rather than specific embodiments.
Reasoning: The district court favored MWV’s definition, stating that 'rapidly cooled' aligns with the term’s ordinary meaning and is not restricted to liquid cooling mediums.
Expert Testimony Admissibilitysubscribe to see similar legal issues
Application: The court upheld the district court's decision to allow expert testimony on XRD crystallinity, finding no abuse of discretion despite deviations from the specified testing protocol.
Reasoning: Consequently, the court affirmed the decision to allow Dr. Reibenspies to testify, finding no abuse of discretion by the district court.
Indefiniteness Waiversubscribe to see similar legal issues
Application: Rexam and Valois waived their indefiniteness arguments by not pursuing them at trial, leading the court to determine the issue was abandoned.
Reasoning: Rexam and Valois waived their indefiniteness arguments by not pursuing them at trial.
Patent Infringementsubscribe to see similar legal issues
Application: The court affirmed findings of infringement on the generic dispenser claims of the '132 patent, rejecting Valois and Rexam's arguments about non-infringement.
Reasoning: The court upheld the district court’s infringement finding, emphasizing that Valois’s argument about the 'New' tube being extruded into 'warm ambient air' was unfounded.
Summary Judgment on Nonobviousnesssubscribe to see similar legal issues
Application: The Federal Circuit vacated the district court's summary judgment of nonobviousness, finding that material factual disputes existed that warranted a trial.
Reasoning: The Federal Circuit found that the district court erred in granting summary judgment of nonobviousness in favor of MeadWestvaco, leading to the vacating of that ruling.