Federal Circuit Upends Two Infringement Judgments

In Smartrend Manufacturing Group (SMG), Inc. v. Opti-Luxx Inc., the Federal Circuit vacated a finding of design patent infringement due to an erroneous claim construction. The panel also reversed the district court's denial of JMOL on infringement under the doctrine of equivalents (DOE), finding the accused products failed to perform a function required by the asserted utility patent.

Background

Smartrend Manufacturing Group (SMG) sued Opti-Luxx for allegedly infringing a design patent and a utility patent, which cover illuminated school bus signs. The district court ruled in favor of SMG on both patents, denied Opti-Luxx's motion for JMOL, and entered a permanent injunction against Opti-Luxx. Opti-Luxx appealed, challenging the district court's claim construction for the design patent and the finding of infringement under the doctrine of equivalence for the utility patent.