Board’s obviousness finding was predicated on erroneous finding that claim term “mechanical control assembly” was not a means-plus-function term.
The Patent Trial and Appeal Board erred in finding that the term “mechanical control assembly” used in two independent claims of a patent directed to a steering and driving system for zero turn radius vehicles had a sufficiently definite structure in the specification to evade § 112, ¶ 6, the U.S. Court of Appeals for the Federal Circuit has held. The Board conflated corresponding structure in the specification with a structural definition for the term and gave improper weight to out-of-context statements in the prosecution history. The Board’s obviousness finding predicated on erroneous claim construction was reversed and the case remanded (MTD Products Inc. v. Iancu, August 12, 2015, Stoll, K.).
Case date: 12 August 2019
Case number: No. 2017-2292
Court: United States Court of Appeals, Federal Circuit
A full summary of this case has been published on Kluwer IP Law.