Molo Design, Ltd. v. Chanel, Inc.

Background

Molo Design, Ltd. alleged that Chanel, Inc. infringed claims in two patents: United States Patent No. 7,866,366, concerning an article of flexible furniture used to partition a room, and United States Patent No. 9,689,161. This opinion concerned claim construction—the court’s interpretation of the words used in a patent claim— for two terms in claim 1 of the ’366 Patent: “supports” and “self-supporting.”

The ’366 Patent describes flexible furniture with a cellular core made from connected laminar panels. Claim 1 refers to supports at opposite ends of the core that are connected to the panels, provide rigidity, can be moved apart to expand the core, and can be folded into a tubular configuration.

Chanel had previously obtained a stay while the Patent Trial and Appeal Board reviewed the asserted patents. The Board found some claims of other patents unpatentable but did not find the challenged claims of the ’366 Patent unpatentable. After the stay was lifted, Molo proceeded with a narrower set of claims.

Agreed Constructions

The court adopted the parties’ agreed meanings for several terms. It construed “operable to maintain . . . and permit” as “capable of maintaining . . . and permitting”; “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 described the supports’ location, connections, functions, and physical characteristics. Chanel proposed defining the term as “supporting panels that are different from the laminar panels that form the core.”

The court declined to further construe “supports.” It concluded that the claim’s language made the term’s meaning sufficiently clear and did not require the supports to be panels separate from the core’s laminar panels. The court also found that Chanel’s proposed additional requirements would add unspecified terms and potentially confuse the jury.

“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 rejected Molo’s proposed construction. It reasoned that Molo’s definition focused only on the supports’ ability to support the core and effectively removed the word “self” from “self-supporting.” The court also relied on the patent specification, which repeatedly described “self-supporting” as an object’s ability to support itself.

The court therefore construed “self-supporting” as “able to stay upright and resist collapse without being supported by something else.”

Disposition

The court adopted the agreed constructions, declined to construe “supports,” and construed “self-supporting” according to Chanel’s proposed definition. The opinion addressed claim meaning and did not determine whether Chanel infringed the patents.