A Patent Claim for a Removable Car Seat Did Not Require Easy Removal, But the Function as a Seat After Removal Was a Disputed Question of Fact

Case: Dorel Juvenile Group, Inc. v. Graco Children's Prods., Inc., No. 05-1026 (Fed Cir. 11/7/05)

The One Sentence Summary: Over a dissent by Judge Newman, the Federal Circuit panel held that a child's car seat did not need to be easily removable in order to infringe patent claim language providing for a seat "removably attached" to a base, but the district court erred in granting summary judgment of non-infringement due to factual questions for the jury about whether the seat could function as a seat once removed.


What They Were Fighting About: Dorel's patent claimed a car seat with a retractable cup holder where the seat was removably attached to a base. Graco claimed that its car seats could not infringe because the seat could only be removed from the base by disassembly, and one of its seats required removal of upholstery and use of a special one-way screw driver. The district court granted summary judgment of non-infringement.

Federal Circuit Holdings:

• The district court properly construed the claim language in rejecting an argument that the seat be easy to detach from the base. The language "removably attached" did not require ease of removal.
• The district court properly construed the claim as requiring the seat to function as a seat once removed. However, the district court erred in finding that the accused seats could not infringe because they did not function as seats after removal. This was a question of fact for the jury.