Dometic Corp. v. ITC
Panel: Taranto, Clevenger, Stoll
The Federal Circuit affirmed the International Trade Commission's denial of relief to Dometic Corp. and Dometic Sweden AB in their Section 337 investigation involving U.S. Patent No. 8,056,351, which covers marine air conditioning systems. The Commission found claims 1–2, 4–5, and 7 anticipated by prior art and determined that neither the accused products nor Dometic's domestic industry products practiced claims 18–22. Dometic appealed both rulings, arguing the Commission applied incorrect claim constructions in each instance.
The court applied the Becton presumption that separately recited claim elements ordinarily imply distinct components, but found the presumption rebutted by intrinsic evidence in both disputes. For the anticipation ruling, the court held that the "assembly" need not be physically disjoint from the "main body" despite their separate recitation, allowing a component (the shroud) to serve as the "guiding cover" within the assembly even if integrated with the main body. For the non-infringement ruling on claims 18–22, the court endorsed the Commission's construction requiring two distinct modes of blower rotation—one for the blower itself and another for the duct element rotating around the guiding cover—finding support in the claim language differentiating the "first axis" (blower rotation) from the "second axis" (assembly adjustment). The court reviewed claim construction de novo based solely on intrinsic evidence under Teva.