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Solvay, S.A. v. Honeywell Specialty Materials LLC

Citations: 591 F. Supp. 2d 724; 2008 U.S. Dist. LEXIS 99198; 2008 WL 5157478Docket: Civ. No. 06-557-SLR

Court: District Court, D. Delaware; December 8, 2008; Federal District Court

Narrative Opinion Summary

The case involves a patent infringement lawsuit filed by Solvay, S.A. against Honeywell Specialty Materials LLC and Honeywell International Inc., concerning U.S. Patent No. 6,730,817. The patent covers processes for producing the environmentally friendly hydrofluorocarbon HFC-245fa. Solvay claims that Honeywell's Geismar process infringes specific claims of the patent. Both parties filed cross-motions for summary judgment, with Solvay seeking confirmation of infringement and Honeywell arguing for non-infringement. The court, having jurisdiction under 28 U.S.C. § 1338, granted Solvay's motion for summary judgment regarding the infringement of Claim 1, citing that Honeywell's process met the broad construction of the patent claims. Conversely, the court granted Honeywell's motion for non-infringement concerning Claim 12, as the Geismar process failed to satisfy specific limitations of retaining certain compounds in the reactor. The decision upheld Solvay's summary judgment for Claim 1 and Honeywell's for Claim 12, affecting related dependent claims.

Legal Issues Addressed

Claim Construction and Infringement

Application: The court found that Honeywell's Geismar process infringes Claim 1 due to the broad claim construction that included the presence of other materials in the gas stream.

Reasoning: Regarding Independent Claim 1 of the '817 patent, it describes a process for preparing HFC-245fa... The court concludes that the Geismar process does infringe Claim 1 of the '817 patent, consistent with the issued claim construction order.

Literal Infringement

Application: Literal infringement occurs if every limitation of at least one patent claim is present in the accused product.

Reasoning: Literal infringement exists if every limitation of at least one patent claim is present in the alleged infringer’s product.

Non-Infringement Due to Claim Limitations

Application: The court determined that the Geismar process does not infringe Claim 12 of the '817 patent because it did not meet the 'keep in the reactor' limitation.

Reasoning: Claim 12, which details a process for preparing HFC-245fa... However, the specification clarifies that this language does not extend to the limitations of claim 12. Consequently, the court determines that the Geismar process does not infringe claim 12, granting Honeywell’s motion for summary judgment on noninfringement.

Patent Infringement Analysis

Application: The court undertakes a two-step analysis where it first interprets the asserted claims of a patent and then compares them with the accused product.

Reasoning: In patent infringement cases, infringement occurs when a person makes, uses, or sells a patented invention without authority. A two-step analysis is employed: first, the court construes the asserted claims to determine their meaning, which is a legal question subject to de novo review. Second, the trier of fact compares the claims with the accused product, which is a factual question.

Summary Judgment in Patent Litigation

Application: Summary judgment is granted when there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law.

Reasoning: Summary judgment is granted when there is no genuine issue of material fact, with the moving party carrying the burden of proof on this matter.