Cuozzo Speed Technologies, LLC v. Lee

Cuozzo Speed Technologies, LLC (plaintiff) applied for a patent covering a speedometer that would show a driver when the driver was driving above the speed limit. The United States Patent and Trademark Office (the Patent Office) (defendant) granted the patent. Garmin International, Inc. filed a petition seeking inter partes review of Cuozzo’s patent. Garmin stated that Cuozzo’s patent was obvious in light of three prior patents. The Patent Trial and Appeal Board (the board) agreed with Garmin. The board stated that each of the prior patents described an aspect of Cuozzo’s invention, and that anyone with ordinary skill and ordinary creativity could have combined the ideas in the patents to create Cuozzo’s invention. Cuozzo appealed to the United States Court of Appeals for the Federal Circuit. Cuozzo argued that the board improperly used the wrong standard when construing the claims in Cuozzo’s patent. Cuozzo argued that although the board followed the standard set forth in the Patent Office’s regulation and gave the patent’s claims their broadest reasonable construction, the board should have applied the standard that courts normally use when judging a patent’s validity. This standard required courts to give claims their ordinary meaning as understood by a person of skill in the art. The court rejected Cuozzo’s argument and affirmed the application of the broadest-reasonable-construction standard. The court held that the Patent Office’s regulation was a reasonable, and hence lawful, exercise of its statutorily granted rulemaking authority. The Supreme Court granted Cuozzo’s petition for cert.