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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 Cir., No. 2016-2713, unpublished 1/25/17 ).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.
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