Largan Precision Co, LTD v. Motorola Mobility, LLC.

Background

Largan sued Motorola for patent infringement. After the case was stayed while the United States Patent Trial and Appeal Board considered Motorola’s six petitions for inter partes review, Largan narrowed the asserted claims. The opinion states that Largan asserted claims 16–20 and 22–24 of U.S. Patent No. 8,310,767 and claim 5 of U.S. Patent No. 9,784,948.

The patents concern imaging lens systems. The ’767 Patent generally describes systems with six lens elements, while the ’948 Patent generally describes systems with five lens elements. The parties presented claim-construction disputes, meaning disputes about the meaning and scope of words used in the patent claims.

Legal standard

The court explained that claim construction is a legal question for the court. Patent claim terms generally receive their ordinary meaning as understood by a person skilled in the relevant technology, unless the patent clearly redefines a term or gives up part of its ordinary scope. The court primarily considers the patent claims, the patent specification, and the patent’s examination history.

Construction of “convex . . . surface” and “concave . . . surface”

Largan proposed construing these terms to mean a “surface that is convex/concave where the surface intersects the optical axis.” Motorola argued that the terms were indefinite, meaning they failed to tell skilled readers with reasonable certainty what was within the claims.

The court rejected Motorola’s indefiniteness argument. It reasoned that the patents refer to the portion of a lens surface near the optical axis, and that this portion must include the point where the surface intersects the optical axis. Because a portion described as convex or concave must be wholly convex or wholly concave, the court concluded that a skilled person would determine the relevant characteristic at the intersection with the optical axis.

The court therefore adopted Largan’s proposed construction: “surface that is convex/concave where the surface intersects the optical axis.”

Construction of the fifth-lens-element limitation

The disputed term in claim 16 of the ’767 Patent describes “a fifth lens element with positive refractive power having a convex image-side surface” and requires at least one of its surfaces to be aspheric. Largan argued that the term needed no construction and should retain its plain and ordinary meaning. Motorola proposed adding a requirement that the fifth lens element also have a concave object-side surface.

The court rejected Motorola’s proposed addition. It explained that the limitation did not appear in the claim language and that importing a feature from particular embodiments described in the specification would improperly narrow the claim. The court also found no persuasive basis for treating the claim language as implicitly redefined to require a concave object-side surface.

The court concluded that this term needed no construction.

Disposition and scope of the order

The court adopted the construction for “convex . . . surface” and “concave . . . surface,” and found that the fifth-lens-element term needed no construction. The opinion is a claim construction order; it does not decide whether Motorola infringed the asserted patents.