Broad Language of Honeywell Patent was Limited by Written Disclosure

Case: Honeywell Int'l, Inc. et al. v. ITT Ind. et al., Case No. 05-1407 (Fed. Cir. 6/22/06)

The One Sentence Summary: Affirms summary judgment of noninfringement based on claim limitations found in the written description.


What They Were Fighting About: Plaintiffs' claimed that defendants' quick connects (nut-like structures that join the various components of a fuel injection system together) infringed its patent on a fuel injection system component specially designed for use with electronic fuel injection systems.

Federal Circuit Holdings:

• The claim term "fuel injection system component" was limited to a fuel filter because, on at least four occasions, the written description refers to the fuel filter as being the invention. Thus, the patent did not cover other components of a fuel injection system. Where the written description clearly identifies what the invention is, evidence that the patentee may have said otherwise during prosecution, is entitled to little weight.
• Because the patent was limited to fuel filters, the allegedly infringing product, quick connects, could not infringe. No reasonable trier of fact could find that quick connects and fuel filters are equivalent devices because, as conceded by plaintiffs, quick connects do not perform the functions of a fuel filter.
• Because the written description demeaned the properties of carbon fibers for the invention, the patentee disavowed carbon fibers from the scope of the patent. Thus, there was no infringement because the accused product used carbon fibers. Where the specification makes clear that the invention does not include a particular feature, that feature is deemed outside the patent, even though the language of the claims might otherwise be more broad.