Opinions — Wednesday, January 14, 2026

The Federal Circuit affirmed summary judgment of noninfringement in favor of Apple Inc. in R.N. Nehushtan Trust Ltd. v. Apple Inc., involving two patents directed to securing cellular devices' "data mode" through a device unique security setting (DUSS). The district court had granted summary judgment on the ground that the patents required the DUSS itself to be sufficient to unlock data mode, a requirement not met by Apple's accused features.

The court's analysis turned on unchallenged claim constructions requiring that the DUSS "grant[] access to a data mode." Relying on intrinsic evidence—particularly specification language stating that "the data mode can only successfully be entered upon correct use of the device unique security setting, and not otherwise"—the panel rejected the patentee's argument that the DUSS need only be one component among many triggering data mode. Because the patentee conceded that Apple's accused features could not, in isolation, unlock data mode as the claim construction required, the court found summary judgment appropriate and declined to reach alternative grounds for affirmance.

The Federal Circuit affirmed the Patent Trial and Appeal Board's obviousness rejection of claims in Blue Buffalo Enterprises, Inc.'s patent application directed to a packaging container for wet pet food. The central dispute turned on claim construction: whether "configured to" and "configured for" should be construed as "capable of" performing a recited function or as requiring that a structure be "specifically designed to" perform that function.

The court's analysis is notable for its treatment of context-dependent claim construction principles. Blue Buffalo relied on Giannelli and Aspex Eyewear, but the court distinguished those cases on two grounds: they construed "adapted to" rather than "configured to," and in both, the specification supplied context supporting a narrower construction than mere capability. Here, Blue Buffalo pointed to nothing in the claims or specification indicating that "configured to" meant more than "capable of," and the specification's disclosures were consistent with the Board's broader construction. The court's approach underscores that even functionally similar terms like "adapted to" and "configured to" may carry different meanings, and that specification context is decisive in determining whether to narrow a construction beyond structural capability.