Backyard Nature Products, Inc. v. Woodlink, Ltd.

Backyard Nature Products, Incorporated (Backyard) (plaintiff) held a patent on a specific bird-feeder design. The design included a floor with upturned edges, and one of the patent’s claims was that the bird feeder had an “apertured floor member” that connected to the bird feeder’s vertical walls. The patent specifications described the apertured floor member as a “tray-like member” formed from a flat sheet. Woodlink, Limited (defendant) made and sold bird feeders with a similar design, but Woodlink’s feeders used a flat sheet-type floor with no upturned edges. Backyard sued Woodlink for patent infringement in the United States District Court for the Eastern District of Wisconsin. Woodlink moved for summary judgment of noninfringement. The district court construed the patent claim’s language of an apertured floor member as requiring at least one raised or upturned edge. Based on that construction, because Woodlink’s bird feeders had a flat sheet floor without upturned edges, the district court found that Woodlink’s bird feeders didn’t literally infringe Backyard’s patent. Furthermore, the district court found that Woodlink’s sheet floor was not equivalent to an apertured floor member and thus that Woodlink also did not infringe Backyard’s patent under the doctrine of equivalents. Backyard appealed, arguing that an apertured floor member did not require an upturned edge.