Brilliant Instruments, Inc. v. Guidetech, LLC

GuideTech, LLC (GuideTech) (plaintiff) owned three patents for circuits for measuring timing errors of digital, high-speed processor signals. The circuits contained capacitors that operated in parallel with first-current circuits. The inventor of the patents founded Brilliant Instruments, Inc. (Brilliant) (defendant) and began selling products for the same purpose but having capacitors within their first-current circuits. Brilliant sued for declaratory judgment that GuideTech’s patents were not infringed by its products. The district court construed GuideTech’s claims’ term “operatively disposed in parallel” to mean “arranged in a manner capable of forming alternative paths of current such that current can flow across one path or the other path.” Neither party disputed the construction. GuideTech’s expert conceded that Brilliant’s capacitor was within its first-current circuit and not on an alternative current flow path from the first circuit. However, the expert’s report explained how operation of Brilliant’s product was equivalent to that of GuideTech’s. Because Brilliant’s capacitor was in the first circuit and not operatively disposed in parallel with it, the district court concluded Brilliant’s product did not infringe literally or under the doctrine of equivalents. Summary judgment was granted in favor of Brilliant. GuideTech appealed.