Eidos Display, LLC v. AU Optronics Corp.
Addressing indefiniteness in a post-Nautilus world, the
U.S. Court of Appeals for the Federal Circuit concluded that the
claim limitation "a contact hole" could refer to
multiple, separate contact holes and was not indefinite under the
"reasonable certainty" standard at Nautilus.
Eidos Display, LLC v. AU Optronics Corp., Case No.
2014-1254 (Fed. Cir., Mar., 10, 2015) (Chen, C.J.).
Eidos accused various electronic display manufacturers (the
display manufacturers) of infringing its patent directed to
manufacturing an electro-optical device, such as a liquid crystal
display (LCD). After the Markman phase, the district court granted
the display manufacturers' motion for summary judgment that the
claim limitation "a contact hole for source wiring and gate
wiring connection terminals" was indefinite. Eidos
argued that this "contact hole" limitation required
multiple holes. In contrast, the display manufacturers argued that
a