There's a Fine Line Between Claim Construction and Importing Limitations

HSBC Finance Corporation v. Decisioning.com, Inc., [2007-1308] (May 7, 2008) [MAYER, SCHALL, and LINN] The Federal Circuit affirmed in part and vacated in part summary judgment of non-infringement.
SIGNIFICANCE: There is a fine line between reading a claim in light of the specification, and reading a limitation into the claim from the specification
BRIEF: The district court construed the term “remote interface” as “dedicated computer equipment, meaning equipment supplied by the entity providing the financial account or service . . . .”. It construed “verify the applicant’s identity” as follows: “to confirm or substantiate the applicant’s identity. The Federal Circuit acknowledged acknowledged that “there is sometimes a fine line between reading a claim in light of the specification, and reading a limitation into the claim from the specification.”
The Federal Circuit said that the plain and ordinary meaning of the term “remote interface” is admittedly broad. Divorced from the specification, it could encompass almost any user interface that is located remotely from the data processing system. However, read in light of the specification, it concluded that one of ordinary skill in the art would not understand the term “remote interface” to encompass a consumer-owned personal computer. Further, the Federal Circuit observed that the claims are not limited to the preferred embodiment disclosed. As a result the Federal Circuit generally agreed with the district court’s construction but removed some limitations that were not supported by the specification.
The district court’s claim construction was modified in accordance with this opinion. The district court’s summary judgment of non-infringement in favor of the Federated Appellees is affirmed. The district court’s summary judgments of non-infringement in favor of the HSBC and TD Ameritrade Appellees were affirmed-in-part and vacated-in-part, and the case remanded for further proceedings.