ADM Edible Bean Specialties, Inc. v. American Bean LLC

Background

ADM alleged that American Bean infringed five patents covering the Radiant, Vibrant, Cowboy, Gleam, and Lumen pinto bean varieties. The asserted claims included claims for the seeds, plants grown from those seeds, and methods of planting or processing them. The parties jointly sought claim construction, the court’s determination of the legal meaning and scope of disputed patent claim terms.

“Plurality”

The parties disputed the meaning of “a plurality of the edible bean seeds of claim 1” in claim 10. ADM proposed the ordinary meaning, “two or more.” American Bean proposed a definition requiring an essentially homogeneous population that was at least 95% of the relevant bean seed.

The court adopted ADM’s construction: the phrase means “two or more edible bean seeds of claim 1.” The court relied on Federal Circuit decisions and dictionary definitions stating that “plurality” means more than one. It also found that the patent language concerning a potentially homogeneous population and “95% or more” described a particular embodiment, did not define “plurality,” and could not be imported as a limitation into claim 10.

Variety names

American Bean initially proposed detailed constructions for the names “Cowboy,” “Vibrant,” “Radiant,” “Lumen,” and “Gleam.” After ADM filed its claim-construction brief, American Bean acknowledged that its initial constructions were incorrect and proposed a different, single construction. The court treated that new proposal as a request to amend the earlier construction but concluded that American Bean had not shown the required good cause to make the late change. The court therefore did not consider the second proposed construction.

The court also declined to adopt the initial constructions because American Bean had conceded they were incorrect and because the names were merely designations for particular patented pinto bean varieties, not technical claim language requiring explanation. The court held that all five name terms require no construction.

Disposition

Judge Jeffrey M. Bryan ordered that ADM’s request for claim construction was GRANTED as follows: “a plurality of the edible bean seeds of claim 1” in claim 10 means “two or more edible bean seeds of claim 1,” and “Cowboy,” “Radiant,” “Vibrant,” “Lumen,” and “Gleam” require no construction. The order resolved the disputed claim meanings but did not decide the ultimate patent-infringement claims.