Izumi Products v. Koninklijke Philips (Fed. Cir. 2005) (NONPRECEDENTIAL)
In the wake of the CAFC’s recent foray into disposable razors, the appellate panel has now made its mark on the world of electric rotary razors.
In 2002, Izumi sued Philips for infringement of its electric razor patent that discloses a specialized recess in the blade that helps ensure that “shaving debris” don’t adhere to the blades. After construing the claims, the district court granted summary judgment of non-infringement in Philips favor. On appeal, the CAFC (Lourie, Newman, JJ.) found an error in the district court’s claim construction based on their review of the patent specification and logical analysis, but without any mention of a dictionary analysis.
In a concurring opinion, Judge Linn remarked the disputed term, “recess,” should be given the “full scope of its ordinary and customary meaning” and not be limited by definitions “improperly read” from the specification.