INNOVA / Pure Water v. Safari Filtration Systems (Fed. Cir. 2004) (CLEVENGER, Rader, and Linn, JJ.)
Innova sued Safari for infringement its patented water filter assembly. (U.S. Patent No. 5,609,759). After construing the claims, the District Court (M.D. Florida) granted Safari’s motion for summary judgment of noninfringement.
Innova’s appeal with patent turns on the correct interpretation of the disputed claim term, “operatively connected.” In particular, Innova challenged that the District Court improperly imported a “tenacious physical engagement” limitation into claim language that does not require any such thing. The Appellate Panel agreed and vacated the decision in-part.
The district court erred. The asserted claims do not require that the filter tube and cap be affixed to one another in a manner that results in the two components forming a unitary structure. Neither party asserts that the term “operatively connected” is a technical term having a special meaning in the art of water filtration. Rather, it is a general descriptive term frequently used in patent drafting to reflect a functional relationship between claimed components. Generally speaking, and as used in the ‘759 patent, it means the claimed components must be connected in a way to perform a designated function. In the absence of modifiers, general descriptive terms are typically construed as having their full meaning.
Remanded for further proceedings.