Access practice tools, as well as industry leading news, customizable alerts, dockets, and primary content, including a comprehensive collection of case law, dockets, and regulations. Leverage...
By Tony Dutra
Ryobi can continue to sell its WiFi-enabled garage door openers while a patent infringement case continues, an appeals court ruled Jan. 25 ( Chamberlain Grp., Inc. v. Techtronic Indus. Co. , 2017 BL 20658, Fed. Cir., No. 2016-2713, unpublished 1/25/17 ).
The U.S. Court of Appeals for the Federal Circuit held that Techtronic Industries Co., which makes Ryobi-branded products, has raised a substantial case for the invalidity of the patent underlying competitor Chamberlain Group Inc.’s smartphone-control technology.
The case was remanded to the district court, where CGI will have to overcome the challenge to that patent. Techtronic will also face charges it infringes a second CGI patent.
CGI’s Liftmaster has approximately 70 percent share of the professionally installed garage door opener market. Its modern line of products features MyQ technology, protected by U.S. Patent Nos. 7,224,275 and 7,635,966 and enabling Wi-Fi connections to the device’s controller.
Hong Kong-based Techtronic introduced the competing Ryobi GD200 garage door opener in May 2016. CGI filed a patent infringement lawsuit soon after in the U.S. District Court for the Northern District of Illinois and asked for a preliminary injunction.
CGI was required to show both a substantial likelihood of success on the merits of its infringement claim and irreparable harm absent the injunction. U.S. District Judge Harry D. Leinenweber determined that CGI adequately made its case and granted the motion.
However, the Federal Circuit overturned Leinenweber’s claim construction ruling, which defined the terms used in the patent. The issue was whether the claims described a door opener that could operate solely in “self-aware” mode, determining and transmitting status conditions—such as open, closed, moving or obstructed—without relying on the use of external sensors. If not, Techtronic had raised a substantial question of the validity of the asserted claims, because the prior art disclosed units that responded to input provided by sensors.
The appeals court searched the written description of the patent and saw only one reference to “self-aware.” The sentence containing the reference made clear that the door opener need not be self-aware, and that it could also use external information about the unit’s condition.
The district court had said its construction, determined to be incorrect, was the sole basis for CGI’s likelihood of success, the appeals court said.
Judge Alan D. Lourie wrote the court’s nonprecedential opinion, which was joined by Judges Richard G. Taranto and Raymond T. Chen.
Fish & Richardson PC, Redwood City, Calif., represented CGI. Morgan, Lewis & Bockius LLP, Chicago, represented Techtronic.
To contact the reporter on this story: Tony Dutra in Washington at firstname.lastname@example.org
To contact the editor responsible for this story: Mike Wilczek at email@example.com
Copyright © 2017 The Bureau of National Affairs, Inc. All Rights Reserved.
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to firstname.lastname@example.org.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to email@example.com.
Put me on standing order
Notify me when new releases are available (no standing order will be created)