Specification Provides Proper Construction To Resolve Ambiguities In Claim Language

In World Class Technology Corp. v. Ormco Corp., Nos. 13-1679, 14-1692 (Fed. Cir. Oct. 20, 2014), the Federal Circuit affirmed the district court's construction of the claim term "support surface" and the stipulation of noninfringement.

Ormco Corporation ("Ormco") owns U.S. Patent No. 8,393,896 ("the '896 patent"), which describes a bracket that attaches to a tooth for orthodontic braces. The '896 patent states that the bracket includes a slot to hold an archwire that connects the teeth, with a slide that moves across a slot opening to hold the wire in place. The specification also explains that the slide moves at an angle away from the gums, avoiding gum contact, when moving from a slot-closed to a slot-open position.

World Class Technology Corporation filed for DJ for noninfringement of five patents owned by Ormco. Ormco counterclaimed, alleging infringement of the '896 patent and seeking a preliminary injunction. During claim construction, the parties disputed the meanings of the terms "support surface" and "ledge" in independent claim 1 of the '896 patent. The district court denied the preliminary injunction and found that the "support surface" "at least partially supports and guides the movable member [slide] during movement between the open position and the closed position." Slip op. at 5 (quoting World Class Tech. Corp. v. Ormco Corp., 964 F. Supp. 2d 1273, 1280, 1285 (D. Or. 2013)). The district court also adopted a complementary construction of the term "ledge" as contacting the slide only when the slide is in the closed position. The parties stipulated to noninfringement under the district court's "support surface" construction. The parties also stipulated to noninfringement of the other five patents. The district court entered a final judgment. Ormco appealed.

"Where, as here, the claim language itself leaves interpretive questions unanswered, '[t]he construction that stays true to the claim language and most naturally aligns with the patent's description of the invention will be, in the end, the correct construction.'" Slip op. at 7-8 (alteration in original) (quoting Renishaw PLC v. Marposs Societa' per Azioni, 158 F.3d 1243, 1250 (Fed. Cir. 1998)).

On appeal, the Federal Circuit found that the term "support surface" does not, by itself, have a clear, unambiguous meaning with respect to the support surface's role during movement of the slide. The Court reasoned that although the claim term "requires a surface that provides...