Woodway USA v LifeCore Fitness
Panel: Lourie, Hughes, Stoll
The Federal Circuit affirmed the PTAB's determination that claims 30–34, 37–39, 41, 45–49, 57, and 59 of Woodway's patent on manually operated treadmills are unpatentable as obvious over a combination of prior art references. The central dispute concerned whether Chickering's single-belt treadmill disclosed a "curved running surface" as claimed; Woodway argued the term should be limited to surfaces where a runner's feet would typically make contact during normal use, thereby excluding Chickering's curved transition area between forward and rearward rollers.
The court's analysis turned on the distinction between claim construction disputes and factual findings about prior art disclosures under the Graham factors. The panel rejected Woodway's attempt to reframe what was essentially a factual dispute about Chickering's disclosures as a claim construction issue warranting de novo review, holding that the Board made factual findings rather than adopting an implicit construction. Even assuming the Board's analysis constituted an implicit construction, the court found Woodway's proposed limitation inconsistent with the specification, which described the running surface as a continuous surface encompassing multiple regions with varying geometric configurations, whether or not those regions would typically be contacted by a runner's feet. The court also rejected Woodway's teaching-away and secondary considerations arguments, finding substantial evidence supported the Board's motivation to combine and its determination that Woodway failed to establish nexus between the claimed features and alleged commercial success.