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Meade Instruments v. Yamcon

Posted in Opinion Commentary by Jake Ward on August 27, 2006

Directional Arrows Provided by the Accused Device Were Not “Data” Within the Meaning of the Claims. 

(Fed.Cir. 2006, 05-1555), non-precedential

The District Court (C.D. Cal.) granted summary judgement for Yamcon under a holding of non-infringement of Meade U.S. Pat. No. 5,311,203 (the 203 patent).  On appeal, the CAFC upheld the claim construction of the district court and the finding of non-infringement of the 203 patent.

The 203 patent technology relates to a handheld device for locating and identifying visible celestial objects.  The accused Yamcon product (the “Skyscout”) is also a handheld device with an eyepiece to see a portion of the sky.  The Yamcon device also has a find mode with directional arrows for finding objects.  Notably, the display screen of the device is situated on one side and not in the user’s field of view.

In particular, Meade challenged the construction of term “data” and the requirement that the data be “simultaneously presented to the user as the user observes the field of view” and “be  provided to the user . . . in real-time as the user observes the field of view of the apparatus.” 

With respect to the “data” term, the CAFC held that the specification made it clear that the term referred to a predetermined set of data entered into the device’s database and “not merely to an abstract bit of data in the broadest sense of the term.”   Thus, the directional arrows provided by the Yamcon device in find mode were not the “data” of the 203 patent.

The CAFC also held that the Yamcon device lacked the “simultaneity” feature of the 203 patent claims.  Because one using the Yamcon device would have to look to the side screen, the data is not presented or provided to the user at the same time as the user observes the field of view.  Regardless of the claim differentation argument made by Meade (narrower dependent claims drawn to real-time displays), the broadest scope that can be construed for the claims at issue does not encompass the Yamcom device.

On this basis, the CAFC concluded that the Yamcom device does not infringe the 203 patent and the summary judgment was upheld.  Affirmed.

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