Federal Court Skeptical of Alleged Flaws in ITC's Patent Violation Judgment Concerning Robotics Technology
The U.S. Court of Appeals for the Federal Circuit (CAFC) has upheld the decision made by the U.S. International Trade Commission (ITC) regarding the infringement of two patents owned by OPEX Corporation. The patents in question are U.S. Patent No. 8622194 and U.S. Patent No. 10576505, which were originally granted to Tesla, Inc.
The dispute centres around HC Robotics' Omnisort Gen 2 delivery system, a robotic system that delivers items via a vehicle that travels along a horizontal track and is lifted into place by an elevator. The ITC determined that this system infringes upon the asserted patent claims for both the '194 and '505 patents.
The '194 patent, titled Material Handling Apparatus for Delivering or Retrieving Items, was at the heart of the appeal. The Federal Circuit found support in the '194 patent specification for the ITC's broader construction of 'first' track that includes the horizontal and vertical legs. They rejected HC Robotics' construction of 'first' track as relying on additional limitations not in the express claim language.
HC Robotics argued for a narrower construction of 'first' and 'track' than the plain and ordinary meaning adopted by the ITC. However, the Federal Circuit's ruling on the '194 patent found that the dictionary definition provided by HC Robotics actually cut against its argument.
For the '505 patent, HC Robotics changed its claim construction argument on appeal, contending that the claimed 'first' drive system cooperable with the guide system should not encompass stationary wheels on a stationary vehicle carried by a lift. The Federal Circuit found this argument unmerited, ruling that the plain claim language requires the drive and guide systems to be cooperable to guide a vehicle to a destination area and maintain vehicle orientation.
The Federal Circuit also rejected arguments that claim construction should be limited by preferred embodiments disclosed in the specification or by statements made during prosecution to distinguish prior art references. They also found no clear and unmistakable waiver of claim scope when HC Robotics argued that statements made by OPEX during patent prosecution narrowed the definition of 'first' in the '194 patent.
On Friday, August 22, the CAFC affirmed the ITC's determination that HC Robotics' Omnisort Gen 2 delivery system infringes upon OPEX's asserted patent claims for both the '194 and '505 patents. This decision upholds the ITC's ruling that a Section 337 violation had occurred through HC Robotics' infringement of these patents. The ITC, in its interpretation of the '194 patent, compared the lifts extending beyond columns to lettuce extending beyond slices of bread in a sandwich.
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