Libman Co. v. Quickie Manufacturing Corp.

Citation: 74 F. App'x 900Docket: Nos. 03-1064, 03-1065

Court: Court of Appeals for the Federal Circuit; August 27, 2003; Federal Appellate Court

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The United States District Court for the Central District of Illinois ruled that Libman Company infringed Quickie Manufacturing Corporation’s U.S. Patent No. 5,502,862, which was issued on April 2, 1996. The appellate court affirmed the trial court's claim construction. Both companies manufacture push brooms, which typically have a threaded handle that attaches to the brush. Quickie’s patent covers a bracket that secures the broom handle by surrounding its hexagonal section, ensuring it remains fixed during use. Libman's Sure Lock bracket employs a "big red bolt" mechanism to secure the handle to the brush, using a distinct design that includes a hexagonal locking feature.

Quickie contacted Libman in September 2000, alleging infringement and requesting a cessation of the Sure Lock product's manufacture and sale. In response, Libman filed for a declaratory judgment of non-infringement and invalidity, while Quickie counterclaimed for infringement, seeking injunctive relief, damages, and attorney fees. During the bench trial, the district court defined the claim terms: it interpreted "means for attaching the bracket body in an upright position" to imply alignment with the broom brush’s threaded hole, and "surround" to mean that the bracket fully encloses the broom handle on all sides.

The district court concluded that Sure Lock did not literally infringe the patent because its "big red bolt" failed to keep the bracket upright and did not enclose the broom handle on all sides, thus not fulfilling parts (b) and (c) of claim 1. However, under the doctrine of equivalents, the court found infringement. The court rejected Libman's arguments for patent invalidity and granted a permanent injunction against infringement, finding no willful infringement and denying attorney fees, as Quickie had waived its damage claims. Libman appealed the ruling, while Quickie cross-appealed, contesting the interpretation of "surround" and the denial of attorney fees. 

The appellate court reviews claim construction without deference, and infringement under the doctrine of equivalents is a factual question. Willful infringement and the determination of an exceptional case are also factual questions, with specific standards for review. Libman did not contest the claim construction or the finding of no literal infringement but focused on the ruling of infringement under the doctrine of equivalents and the validity of the ’862 patent against the ’540 patent. 

The district court found that the "multi-sided bracket opening means" was not a means-plus-function term and that Sure Lock’s notched opening did not literally satisfy the "surround" requirement of part (c). Nevertheless, it determined that the notched opening functioned similarly enough to meet the limitations under the doctrine of equivalents. Libman argued that Sure Lock’s bracket did not fulfill the "completely immobilizes" requirement of part (c), claiming that its design left the broom handle unsupported during use, and contended that the court overlooked the significance of the term "completely."

The district court found that Libman did not provide evidence to support its claim that Sure Lock's broom handle joint is not completely immobilized, thereby rejecting Libman's argument. The court affirmed that Sure Lock meets the requirements of part (c) of the relevant patent claims. Libman also challenged the validity of the ’862 patent in light of U.S. Patent No. 3,183,540 but did not appeal the district court's decision to exclude the ’540 patent from evidence or argue an abuse of discretion. As invalidity was not properly presented at trial, the appellate court declined to consider it. Quickie's cross-appeal contested the district court's definition of "surround," which was interpreted as enclosing the broom handle on all sides based on a dictionary definition from 1995. Quickie proposed an alternative definition from 1984, but the court found no error in the district court's interpretation, supported by the context of the claims. Additionally, the court upheld the district court's findings of no willful infringement and that the case was not exceptional, justifying the denial of attorney fees. The evidence indicated that Libman attempted to design around the patent, modifying the bracket opening under legal advice, which contributed to the decision against awarding fees.