Federal Circuit Redefines Undisputed Plain Meaning Of Claim Term

Addressing the common claim construction issue of whether a claim term should construed consistent with its plain meaning or limited to a disclosed embodiment, the U.S. Court of Appeals for the Federal Circuit redefined a claim term having an undisputed plain meaning and limited it to the disclosed embodiment. Honeywell Int'l, Inc. v. Universal Avionics Systems Corp., Case Nos. 06-1406, -1435 (Fed. Cir., July 3, 2007) (Bryson, J.; Plager, J., dissenting).

The patent-in-suit pertained to aircraft navigational systems for warning airplane pilots of potentially hazardous flight conditions. At issue was the construction of the claim term "heading of the aircraft," specifically the definition of the word "heading." It was undisputed that the word "heading" carried a distinct meaning in the art of navigation; i.e., the direction in which an aircraft is pointed. While Figure 5, which was described in specification as an "important feature" of the invention, disclosed a "bearing"-related