Markman v. Westview Instruments, Inc

Facts

The Petitioner in this infringement suit owned a patent for his inventory control and reporting system for dry cleaning stores. The patent described a system that could monitor and report the status, location and movement of clothing in a dry-cleaning establishment. The system consisted of a keyboard and data processor to generate written records for each transaction and included a bar code readable by optical detectors operated by employees who logged the progress of clothing through the dry-cleaning process. The Respondent’s product, the Exponent, also included a keyboard and processor and it listed charges for the dry-cleaning services on bar-coded tickets that could be read by portable optical detectors. Petitioner brought an infringement suit against Respondent and Althon Enterprises, an operator of dry-cleaning establishments using Respondent’s products. Respondent answered that Petitioner’s patent was not infringed by its system because the Respondent’s system functioned merely to record an inventory of receivables by tracking invoices and transaction totals, rather than recording and tracking an inventory of articles of clothing. Part of the dispute hinged upon the meaning of the word “inventory.” A jury heard the case and heard from one of Petitioner’s witness who testified about the meaning of the claim language. The jury compared the patent to Respondent’s device and found an infringement of Petitioner’s claim. The District Court nevertheless granted Respondent’s deferred motion for judgment as a matter of law, reasoning that the term “inventory” in Petitioner’s patent encompassed both cash inventory and the actual physical inventory of articles of clothing. Since Respondent’s system could not track items it directed a verdict on the ground that Respondent’s device did not have the means to maintain an inventory total and could not detect and localize additions to inventory as well as deletions from it as required by Petitioner’s claim. Petitioner appealed and argued that the District Court erred in substituting its construction of the disputed claim term “inventory” for the construction the jury had given it. The United States Court of Appeals for the Federal Circuit affirmed, holding the interpretation of claim terms to be the exclusive jurisdiction of the court and the Seventh  Amendment of the United States Constitution (Constitution) to be consistent with that conclusion.