Claim construction affirmed, noninfringement judgment reversed

What defines the term \'removably attached\' when referring to a child's safety seat? In a recent case, Dorel Juvenile Group, Inc. v. Graco Children's Products, Inc., the Federal Circuit agreed with a lower court that the seat did not have to be easily removable from its base, as that would add a limitation to the patent claim that was not supported by the patent's specification.The patent at issue involved a child safety seat with a retractable cup holder. The Graco's child seat was removable from its base by unscrewing several screws, and on some models the screws were \'one-way\' such that they required a special screwdriver to loosen. This made the seat \'removably attached\' according to the patent.However, the district court found that the Graco seat did not infringe as a matter of law because it lacked a seat separate from the base, or at least had a seat that was integral to the base. On this point, the Federal Circuit held that the lower court had invaded the jury's duty to find facts. The issue of whether the top and bottom structures of the Graco seat correspond to a \'seat\' and \'base\' in the patent is a question of fact, and it was error for the lower court to decide it on its own as a matter of law.In dissent, Judge Newman stated that the Graco seat is clearly not a base and seat assembly, noting that the two were held together by six one-way screws. Once unscrewed, according to Judge Newman, the seat becomes \'a collection of loose parts,\' and the retractable cup holder becomes incapable of holding a cup. Therefore, Judge Newman would have affirmed the lower court's ruling of noninfringement.To read the entire document, log on to http://fedcir.gov/opinions/05-1026.pdf


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