Broad Claim Scope Survives Despite Single Embodiment Disclosure

Holding that a patentee is entitled to claim scope covering an entire class of devices based on the patent disclosure describing one device of the class, the U.S. Court of Appeals for the Federal Circuit reversed the grant of summary judgment of non-infringement based on a district court’s narrow claim construction, but remanded for further consideration of claim enablement and validity. The Saunders Group, Inc. v. Comfortrac, Inc., Case No. 06-1576 (Fed. Cir., June 27, 2007) (Bryson, J.).

Plaintiff Saunders manufactures cervical traction devices and competes with defendants in the marketplace. Saunders owns a patent directed to a portable cervical traction device and alleged that the defendants were infringing it. The district court granted a summary judgment of non-infringement, construing the claims to be requiring inclusion of at least one pressure-activated seal. The district court arrived at this narrow construction because the patent specification disclosed a single embodiment