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One-E-Way, Inc. v. International Trade Commission

United States Court of Appeals for the Federal Circuit

859 F.3d 1059 (2017)

Facts

One-E-Way, Inc. (plaintiff) filed a complaint with the International Trade Commission (ITC) (defendant) alleging infringement of two of its patents by several entities. The patents claimed wireless audio systems that operated “virtually free from interference” of other wireless audio systems operated in the same spectrum. The patents’ specifications did not define the term virtually free from interference. However, they described systems for private listening without interference from other wireless transmission signals, the same interference identified in the claims. During the patents’ prosecutions, no eavesdropping was given as an example of when the virtually-free-from-interference limitation would be met. The ITC found the term to be indefinite and invalidated all asserted claims including the term under 35 U.S.C. § 112. One-E-Way appealed.

Rule of Law

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Issue

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Holding and Reasoning (Stoll, J.)

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Dissent (Prost, C.J.)

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