Harmonic Design, Inc. v. Hunter Douglas, Inc.

Citations: 88 F. Supp. 2d 1102; 2000 WL 283693Docket: CV 99-02921 WJR (RCX), CV 98-7477 WJR (RCX)

Court: District Court, C.D. California; February 9, 2000; Federal District Court

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Harmonic Design, Inc. filed a motion for the court to interpret claim terms in a patent infringement case against Hunter Douglas, with a hearing held on January 31, 2000. The court outlined the two steps in patent infringement analysis: first, determining the meaning and scope of the asserted patent claims, and second, comparing these claims to the allegedly infringing device. The court emphasized that claim construction is a legal issue, relying on intrinsic evidence, including the claims' language, specifications, and prosecution history, while giving terms their ordinary meaning as understood by someone skilled in the relevant art.

The court also addressed the application of 35 U.S.C. § 112, paragraph 6, which allows claims to be expressed in means-plus-function format without detailing the structure, material, or acts. A presumption exists that this provision does not apply if the phrase "means for" is not used, though this presumption can be rebutted with sufficient evidence. The focus remains on whether the claim conveys a sufficiently definite structure.

The term "electronic circuit" in various claims of three different patents is in dispute, particularly whether it is in means-plus-function format. Claim 1 of the '855 Patent was cited as representative of the claims in question. The claim describes a window covering with an actuator that includes an electronic circuit connected to a control signal generator and battery for processing signals to activate a motor.

The term "electronic circuit" possesses a sufficiently definite structure to bypass the application of 35 U.S.C. § 112, paragraph 6, as the disputed claims do not employ "means for" language. The ordinary definition of "circuit" refers to an arrangement of interconnected electronic components performing specific functions with appropriate voltages and signals, a definition supported by court rulings. Specific claims from two patents detail the electronic circuit's physical connections, reinforcing the notion that it embodies a structural element. Although claims 18 and 28 of one patent do not specify physical location, the court concludes they are not in means-plus-function format. A person skilled in the art would understand "electronic circuit" to align with the established definition.

Regarding microprocessors, there is a contention over whether they qualify as electronic circuits within the claims. Hunter Douglas acknowledges that a microprocessor is generally an electronic circuit but contends that the patent specifications suggest a narrow interpretation aimed at battery conservation that excludes microprocessors. Harmonic Design previously distinguished between non-logical CMOS components and microprocessors to address an obviousness rejection, emphasizing the higher power consumption of microprocessors, contrary to the patents' objectives. Hunter Douglas argues for an interpretation of "electronic circuit" that excludes microprocessors, citing that Harmonic Design limited its arguments regarding microprocessors to a single dependent claim without asserting that "electronic circuit" broadly excludes them. No claims in the relevant patents reference non-logical CMOS components.

Disputed claims do not necessitate battery-conserving features, contrasting with other claims that do, such as those in the 855 Patent (claims 14, 99) and the 480 Patent (claims 40, 43). It appears Harmonic Design intended to include microprocessors within the term 'electronic circuit.' Hunter Douglas concurs with this interpretation. A microprocessor, defined as an integrated circuit for data manipulation and decision-making, qualifies as a type of electronic circuit, supported by definitions from the IEEE Standard Dictionary. Therefore, the Court concludes that 'electronic circuit' encompasses microprocessors.

The term 'control signal generator' in multiple claims of the 855 and 480 Patents is also in contention. The claims do not utilize the phrase 'means for,' indicating that 35 U.S.C. 112.6 does not apply. Harmonic Design has not provided a dictionary definition for 'control signal generator,' but the term is understood to denote a component of an electronic circuit that generates a control signal—defined as any signal that influences data handling by a system. Evidence indicates that the control signal generator is structurally connected to the electronic circuit and battery, suggesting it is a structural element rather than merely functional. Additionally, Figure 7 of the 480 Patent identifies it as part of the electronic circuitry. The term is recognized in the field as having a definite structure, allowing it to circumvent the application of 35 U.S.C. 112.6. Consequently, the Court determines that 'control signal generator' refers to a structural component that produces a control signal.

The term 'the sensor' in claim 107 of the 855 Patent and claims 12, 20, and 47 of the 480 Patent is disputed by Hunter Douglas, who claims these are indefinite under 35 U.S.C. 112.2 due to referencing a non-existent element. However, under 35 U.S.C. 282, patents are presumed valid.

The defendant carries the burden to prove the patent's invalidity through clear and convincing evidence. Indefiniteness is a legal question, determined by whether skilled individuals can understand the claim's scope when viewed alongside the specifications. Claims may lack antecedent basis but can still be definite if clarified by the specifications. In the current case, the claims reference "the electronic circuit [that includes] a switch electrically connected to the sensor," yet neither the disputed claims nor their dependent claims define a sensor element. Hunter Douglas contends that it is ambiguous whether "the sensor" refers to the sensor receiving a control signal from the control signal generator or if it is part of the generator itself. However, the specifications clarify that the sensor is indeed part of the control signal generator. 

Moreover, the specifications distinguish between two types of sensors, but also indicate that these sensors receive signals generated by another sensor through an electrically connected switch. This suggests that the switch receives the control signal from "the sensor." The Court is inclined to rule that the claims are not invalid as indefinite, and that a person skilled in the art would understand "sensor" to refer to a device responding to physical stimuli. Additionally, while Hunter Douglas argues that "electronic circuit" lacks definite structure, the court clarifies that the test is not about precise physical structure but rather the broader understanding of the term within the art, which does not invoke 35 U.S.C. 112, § 6.