Semicaps PTE Ltd v. Hamamatsu Corporation

Background

SEMICAPS Pte Ltd sued Hamamatsu Corporation, Hamamatsu Photonics K.K., and Photonics Management Corp. The opinion refers to these defendants collectively as “Hamamatsu.” SEMICAPS alleged infringement of claims of U.S. Patent No. 7,623,982, which concerns testing electronic circuits with a laser to locate defects on semiconductor circuits.

The order is a claim construction order. Claim construction is the court’s interpretation of the words used in patent claims, which define the scope of the patent rights being asserted. The parties disputed three terms: “value,” “another value,” and “test result.” The court held a technology tutorial and a claim construction hearing before deciding the disputes.

“Value” and “another value”

SEMICAPS argued that both terms should have their plain and ordinary meanings. Alternatively, it proposed defining “value” as “a magnitude, quantity or number” and “another value” as “another magnitude, quantity or number.”

Hamamatsu proposed that “value” mean “a representation of the response signal output by the electronic circuit during the period when the laser beam is radiated.” It proposed a corresponding definition of “another value” tied to a response signal obtained while the laser beam was not radiated.

The court rejected Hamamatsu’s proposed constructions. It found that the patent uses “value” in several ways, including in connection with output voltage, pixel brightness, and response signals during both radiating and non-radiating periods. The court concluded that Hamamatsu was improperly trying to import limitations from particular claims or embodiments into the broader terms. It therefore held that “value” and “another value” require no construction and should receive their plain and ordinary meanings.

“Test result”

SEMICAPS likewise argued that “test result” needed no construction. If construction were necessary, it proposed “determination from the testing of an electronic circuit.” Hamamatsu proposed “determination of whether the circuit is faulty.”

The court rejected Hamamatsu’s proposed definition. It explained that the patent’s discussion of a positive or negative test result and whether a circuit is faulty described a particular embodiment, rather than defining “test result” for every use in the patent. The court also noted that the patent separately describes analyzing an image to determine whether the circuit is faulty, and that this separate analysis is not required by the claim at issue.

The court concluded that “test result” is readily understood according to its plain and ordinary meaning and requires no construction.

Ruling

Judge Donna Ryu concluded that “value,” “another value,” and “test result” require no construction. The order does not adopt any of Hamamatsu’s proposed narrower definitions.