Claim Construction — Dictionaries are Still OK.

PatentlyOImage035North American Container v. Plastipak (Fed. Cir. 2005).

Although this case may be too close on the heels of Phillips v. AWH to serve as a predictor.*  The CAFC affirmed a trial court’s reliance on the Online Oxford English Dictionary when construing the disputed claim term “generally.”  Based on a mostly-proper claim construction by the district court, the CAFC affirmed-in-part a grant of summary judgment of noninfringement. 

* This case did not cite the recent Phillips case.