News & Analysis as of

CAFC Claim Construction

Vorys, Sater, Seymour and Pease LLP

The Precedent: Federal Circuit Clarifies the Importance of Distinguishing Between Functional and Ornamental Features in Design...

The Federal Circuit recently emphasized that patentees must distinguish between functional and ornamental features claimed in design patents or otherwise risk facing a narrowed construction of the patents’ claims....more

Knobbe Martens

Federal Circuit Review | February 2026

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In Range Of Motion Products, LLC v. Armaid Company Inc., Appeal No. 23-2427, the Federal Circuit held that functional aspects of a design must be separated out when analyzing whether an ordinary observer would find two...more

McDermott Will & Schulte

Tree-mendous award: Damages expert royalty opinions are lit

The US Court of Appeals for the Federal Circuit affirmed a damages verdict amounting to tens of millions of dollars. The Court found that the patentee’s damages expert correctly apportioned value to the patented feature and...more

McDermott Will & Schulte

Did you account for the entire corresponding disclosed structure?

The US Court of Appeals for the Federal Circuit affirmed the district court’s grant of summary judgment of noninfringement of a means-plus-function claim element, emphasizing that a patentee must compare the accused product...more

A&O Shearman

Federal Circuit Affirms Summary Judgment Of Non Infringement For Failure To Prove Structural Equivalence Under § 112(f)

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On February 19, 2026, the U.S. Court of Appeals for the Federal Circuit affirmed the District of Delaware’s grant of summary judgment of non infringement in favor of defendants in Genuine Enabling Tech. LLC v. Sony Corp., No....more

Miller Johnson

Spot the Differences: Narrowing Design Patent Scope

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On February 2, 2026, the Federal Circuit affirmed summary judgment of non-infringement in Range of Motion Products, LLC v. Armaid Company Inc., holding that Armaid’s massage device did not infringe Range of Motion’s (RoM)...more

Volpe Koenig

The POSITA Under BRI: The Constraint That Keeps “Broad” from Becoming “Anything”

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Broadest Reasonable Interpretation (BRI), as applied during USPTO examination, is often described as a “broad” claim construction standard. That description is accurate as far as it goes, but it is incomplete in a way that...more

Knobbe Martens

Conceptual Similarity Does Not Go Arm in Arm With Substantial Similarity

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RANGE OF MOTION PRODUCTS, LLC v. ARMAID COMPANY INC. - Before Moore, Cunningham, and Hughes. Appeal from the United States District Court for the District of Maine. Functional aspects of a design must be separated out when...more

Knobbe Martens

Wireless TV Is So Main“stream”

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GOTV STREAMING, LLC V. NETFLIX, INC. - Before Prost, Clevenger, and Taranto. Appeal from the United States District Court for the Central District of California. A winning claim construction isn’t always enough to overcome §...more

McDermott Will & Schulte

The meaning is plain as day: Just follow the grammar

The US Court of Appeals for the Federal Circuit reversed and vacated a decision by the Patent Trial & Appeal Board, explaining that the Board failed to consider common textual modifier language when applying the plain meaning...more

Morgan Lewis

Federal Circuit Upholds Infringement Damages and Validity for Modular Artificial Tree Patent

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In a significant decision providing guidance on the admissibility of expert testimony on patent damages, the Federal Circuit has affirmed both the validity and the substantial-damages verdict for infringement of Willis...more

Knobbe Martens

Presented by Netflix—Grammar Police: An Exercise in Claim Construction

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NETFLIX, INC. V. DIVX, LLC - Before Moore, Dyk, and Taranto. Appeal from the Patent Trial and Appeal Board. Common principles of English grammar may be used to identify the presumptively correct interpretation of a disputed...more

Vorys, Sater, Seymour and Pease LLP

The Precedent: Federal Circuit Affirms That the Order of Method Steps Is Dispositive in Sound View Innovations, LLC v. Hulu, LLC

In Sound View Innovations, LLC v. Hulu, LLC, the Federal Circuit affirmed summary judgment of noninfringement, holding that Hulu’s video streaming technology did not practice the claimed method because it did not perform the...more

Vorys, Sater, Seymour and Pease LLP

The Precedent: Federal Circuit Reverses Exclusion of Expert Testimony and Judgement as a Matter of Law in Barry v. Depuy Synthes...

In Barry v. Depuy Synthes Co., the Federal Circuit reversed the district court’s exclusion of the patentee’s expert testimony and its grant of judgment as a matter of law (JMOL) of noninfringement....more

Fish & Richardson

Be Careful What You Wish For: How Stipulations Become Federal Circuit Issues

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Stipulations are an important tool for simplifying patent cases. They can be used to narrow disputed issues, streamline discovery, and focus trial on what really matters. But stipulations can also take on a life of their own...more

Alston & Bird

Patent Case Summaries | Week Ending February 13, 2026

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Our Patent Case Summaries provide a weekly summary of the precedential patent-related opinions issued by the Court of Appeals for the Federal Circuit and the opinions designated precedential or informative by the Patent Trial...more

McDermott Will & Schulte

Here’s an abstract idea: Patent eligibility depends on what is claimed, not unclaimed disclosure

The US Court of Appeals for the Federal Circuit reversed a district court’s rejection of Netflix’s 35 U.S.C. § 101 challenge, finding that claims directed to tailoring content specifications for wireless devices were patent...more

Sheppard

Federal Circuit Reins In Prosecution Disclaimer in Maquet v. Abiomed

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This case addresses whether the district court correctly applied prosecution disclaimer to (i) import a negative limitation into a child patent claim based on prosecution of a related parent patent with materially different...more

McDermott Will & Schulte

Relax, design patent claim scope doesn’t include functional elements

Addressing the issue of functional versus ornamental features, the US Court of Appeals for the Federal Circuit affirmed the district court’s summary judgment of noninfringement, concluding that no reasonable juror could find...more

McDermott Will & Schulte

Method steps must be done in order where there is logical dependency

In a second appeal, the US Court of Appeals for the Federal Circuit affirmed a district court’s summary judgment of noninfringement based on an implicit ordering of steps in a method claim after disagreeing with the lower...more

McDonnell Boehnen Hulbert & Berghoff LLP

Federal Circuit Misses the Mark on Design Patent Non-Infringement

The district court granted summary judgment of non-infringement, finding that no reasonable jury could find the Armaid2 design to be substantially similar to the design claimed in the D’155 patent. RoM appealed using two main...more

Alston & Bird

Patent Case Summaries | Week Ending February 6, 2026

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Our Patent Case Summaries provide a weekly summary of the precedential patent-related opinions issued by the Court of Appeals for the Federal Circuit and the opinions designated precedential or informative by the Patent Trial...more

Haug Partners LLP

Finding that Expert Testimony “Aligns” with the District Court’s Claim Construction, the Federal Circuit “Backs” Its Admissibility

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On January 20, 2026, the Federal Circuit (per Judge Stark and joined by Judge Taranto, with Judge Prost dissenting) reversed a decision from the Eastern District of Pennsylvania, excluding two experts who testified for...more

Quarles & Brady LLP

When “Functionality” Swallows Design Rights: A Caution for Design Patent Applicants

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The U.S. Court of Appeals for the Federal Circuit’s recent decision in Range of Motion Products v. Armaid is another reminder that, if care is not taken, design patent scope can be narrowed significantly in the U.S. through...more

Schwabe, Williamson & Wyatt PC

Latest Federal Court Cases: Range of Motion Products, LLC v. Armaid Company Inc.

The Federal Circuit’s only precedential decision this week was a rare case involving design patents. The Federal Circuit considered questions concerning infringement and claim construction in view of considerations of...more

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