Molo Design, Ltd. v. Chanel, Inc.

Background

Molo sued Chanel for allegedly infringing claims in two patents, including United States Patent No. 7,866,366, which describes an article of flexible furniture used to partition a room. The disputed terms in this opinion appear in claim 1 of the ’366 patent. The claim describes a flexible article with a core made from connected laminar panels and supports at opposite ends of the core. It states that the supports are “self-supporting” and provide rigidity to the core.

Chanel previously sought review of Molo’s asserted patents by the Patent Trial and Appeal Board. The court stayed the case while that review occurred, later lifted the stay, and noted that Molo dropped claims the Board had determined were unpatentable. The parties then presented proposed meanings for disputed patent terms under the process called claim construction, in which a court interprets the language of patent claims.

Agreed Terms

The court adopted the parties’ agreed construction of “operable” as “capable of maintaining and permitting.” It also adopted the agreed meanings of “major dimension” as “height,” “longitudinal axis” as “vertical axis from top to bottom,” and “freestanding” as “standing alone free of support or attachment.”

“Supports”

Molo argued that “supports” required no additional construction because claim 1 itself describes the supports’ location, connections, rigidity, movement, and flexibility. The court agreed and declined to construe the term further.

Chanel proposed defining “supports” as “supporting panels that are different from the laminar panels that form the core.” The court rejected that proposal because claim 1 does not state that the supports must be panels or that they must be different from the core’s laminar panels. The court also concluded that adding Chanel’s proposed unspecified distinction could confuse the jury rather than clarify the claim.

“Self-Supporting”

Molo proposed defining “self-supporting” as “having sufficient rigidity to resist collapse of the core.” Chanel proposed “able to stay upright and resist collapse without being supported by something else.”

The court adopted Chanel’s construction. It reasoned that Molo’s proposal would remove the ordinary meaning of the word “self” and would describe only the supports’ ability to support the core, not their ability to support themselves. The court also relied on the patent specification, which repeatedly uses “self-supporting” to refer to an object’s ability to support itself.

Disposition

The court adopted the agreed constructions, declined to construe “supports,” and construed “self-supporting” as “able to stay upright and resist collapse without being supported by something else.” Judge Dale E. Ho signed the memorandum opinion and order.