Narrow Claim Construction “Charged” By Specification And Prosecution History

In a case designated by the Court as nonprecedential, the U.S. Court of Appeals for the Federal Circuit reversed a broad claim construction arrived at by the district court, noting that claim differentiation "cannot serve to give a patent scope beyond the invention it discloses."  Black & Decker, Inc. v. Robert Bosch Tool Corp., Case Nos. 07-1243, -1244 (Fed. Cir., Jan.7, 2008) (Prost, J., non-precedential).

The patents-in-suit relate to a combination of a radio and a battery charger.  Bosch appealed from a jury verdict, challenging the district court's broad construction of the term "power conversion circuit."  Bosch contended that the proper construction should require a plurality of DC-to-DC converters that can convert an input DC voltage to a different output DC voltage, either higher or lower, in accordance with the multi-voltage battery charging function of the claim invention.  Black & Decker