Dictionaries Are Not Taboo

Mangosoft, Inc. v. Oracle Corporation, [2007-1250] (May 14, 2008) [LINN, Michel, Prost] The Federal Circuit affirmed summary judgment that Oracle Corporation (“Oracle”) did not infringe Mangosoft’s U.S. Patent No. 6,148,377 (“the ’377 patent”), finding no error in the district court’s construction of the sole claim term raised on appeal.
SIGNIFICANCE: Reference to dictionaries is not prohibited so long as the ultimate construction given to the claims in question is grounded in the intrinsic evidence.
BRIEF: The district court construed several disputed claim terms after holding a Markman hearing. With respect to the term “local,” it held that
the word “local” when used to modify a computer device means a computer device (e.g., a hard drive) that is directly attached to a single computer’s processor by, for example, the computer’s bus. The Federal Circuit said that reference to dictionaries is not prohibited so long as the ultimate construction given to the claims in question is grounded in the intrinsic evidence and not based upon definitions considered in the abstract. The Federal Circuit noted that the patentees’ proposed construction effectively read out the term “local”, which was specifically added during prosecution. The Federal Circuit also found support for the district court’s construction from the specification, including the objects of the invention. Lastly the Federal Circuit found the prosecution history supported the district court’s construction.