Sport Dimension, Inc. v. The Coleman Company, Inc., No. 2015-1553
The Coleman Company, Inc. appealed a stipulated judgment from the Central District of California, which found noninfringement of Coleman’s design patent directed towards “the ornamental design for a personal flotation device.” The Federal Circuit vacated the Central District of California’s judgment of noninfringement based on an erroneous claim construction. Federal Circuit precedent on design-patent claim construction dictates that “where a design contains both functional and non-functional elements, the scope of the claim must be construed in order to identify the non-functional aspects of the design as shown in the patent.” No Federal Circuit precedent completely excluded a functional element from a design-patent claim construction—the claims were simply limited to the “ornamental aspects of the otherwise functional elements.” The Federal Circuit found that the district court correctly found the flotation device’s arm bands and tapered torso to be functional elements, but that the court erred by entirely excluding those components from the claim construction. Rather, the proper construction should identify only the ornamental aspects of the arm band and tapered torso elements. The stipulated judgement of noninfringement was vacated and remanded.