Patent Law Keyed to Adelman
Markman v. Westview Instruments, Inc.
Facts
Plaintiff patented a device that involved attaching bar code labels to each piece of clothing as it comes into a dry-cleaner, then monitoring the progress of each piece of clothing using optical sensors placed throughout the business. Defendant then sold an inventory control system that also created bar-coded tickets for each piece of laundry. The difference was that Defendant's system only kept track of transactions, and was not designed to keep track of the progress of each item. It also did not keep track of additions or deletions from expected inventory. A jury found that Defendant had infringed upon Plaintiff's design for an inventory control system. The district court then stated that the construction of Plaintiff's claim, particularly the term "inventory," was a matter for the court and not the jury. The judge defined "inventory" for purposes of the claim as pieces of clothing, not simply transaction totals, and granted Defendant's motion for judgment as a matter of law. The judgment was upheld by the court of appeals and the Supreme Court granted review.
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