Yuntek International, Inc. v. Xiamen JXD Electronic Commerce Co., Ltd.

Background

The court conducted a technology tutorial and considered briefing related to a hearing under Markman v. Westview Instruments, Inc. The order construes disputed terms in United States Patent No. 6,715,446, titled “Pet Tent.” The patent generally describes a collapsible tent for housing a pet that folds into a storage bag when not in use. The parties disputed five claim terms.

Legal standard

Claim construction—the court’s determination of the meaning and scope of patent claims—is a question of law. Claim terms ordinarily receive their ordinary and customary meaning, meaning the meaning they would have to a person of ordinary skill in the relevant technology at the time of the invention. The court may depart from that meaning if the patent defines the term or the patentee disclaims part of its ordinary scope. The court considered the claim language, the patent specification, and the prosecution history.

Claim constructions

1. “foldable.” Yuntek proposed “having structural features that facilitate folding in the manner described.” The defendants proposed the plain and ordinary meaning. The court rejected Yuntek’s proposal because the asserted claims already contain restrictions describing the folding requirements and adopted the meaning “able to be folded.”

2. “on top of said bottom side [of said main body].” Yuntek proposed “above and directly adjacent to the bottom side of the main body.” The defendants proposed placement onto the interior floor of the housing, including on top of any mat or pad there. The court rejected the proposed additional language and construed the term to mean “directly onto the interior floor of the main body.”

3. “front panel and back panel are folded over the collapsed main body with one of the front panel and the back panel folded over the other.” Yuntek proposed that “folded over” meant bent or pivoted above the collapsed main body and at least partly overlapping the other panel. The defendants proposed folding the panels toward and over each other so that the housing becomes and remains significantly compact. The court construed the phrase to mean that the panels are “bent toward” each other so that one overlaps the other in a compact position above the collapsed main body. The court relied in part on the examination history, which indicated that the compact form distinguished the invention from prior art.

4. “a continuous structure.” Yuntek proposed a structure whose four sides are connected without being disengageable across the structure’s entire length, using examples involving sewing and zippers. The defendants proposed the plain and ordinary meaning. The court rejected Yuntek’s added examples and reference to “four sides” because those additions were not adequately explained, could improperly incorporate preferred embodiments, and could cause confusion where the structure is dome-shaped. The court construed the term to mean “a structure in which all sides of the main body are connected without being fully disengageable.”

5. “wherein said housing is foldable such that.” Yuntek proposed constructions tied to specified passages in the Inter Partes Reexamination Certificate for Claims 6 and 7. The defendants proposed the plain and ordinary meaning. The court explained that “such that” means “in such a way that” and that the three following limitations describe the manner in which the housing is foldable. They do not require that the pet housing actually be folded. The court also found this interpretation consistent with its construction of “foldable” as “able to be folded.”

Case management and disposition

The order resolved the five selected claim-construction disputes. Judge Jeffrey S. White set a case-management conference for July 22, 2022, at 11:00 a.m. and ordered the parties to file a joint case-management conference statement by July 15, 2022.