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Catalina Marketing International v. Coolsavings.com, Inc.
Court of Appeals for the Federal Circuit
289 F.3d 801 (2002)
Catalina (plaintiff) sued Coolsavings (defendant) for infringement of the ‘041 patent, which claimed a system for selecting and distributing discount coupons. The ‘041 patent claims at issue both included the phrase “located at predesignated sites such as consumer stores” prior to the word “comprises” in the claim preamble, referring to the location of the kiosk-like terminals that a consumer would use to select and print discount coupons. Coolsavings permitted internet users to access its website and print coupons for redemption at retailers. Coolsavings argued on summary judgment that the phrase “located at predesignated locations such as consumer” was limiting, which would not prevent Coolsavings from operating its web-based business. The district court agreed and found the ‘041 patent not infringed. Catalina appealed.
Rule of Law
Holding and Reasoning (Rader, C.J.)
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