Design Patent Title Limits Patent Scope, Fed. Cir Says
Written September 18, 2019
The US Court of Appeals for the Federal Circuit on September 12, 2019, held that a Curver Luxembourg SARL’s design patent for a chair was not infringed by home goods company Home Expression. Curver Luxembourg, SARL v. Home Expressions Inc., Fed. Cir., 18-2214, 9/12/19.
Curver alleged that Home Expressions made and sold baskets with an overlapping “Y” design that infringed its design patent. The Federal Circuit found that Curver’s patent on an ornamental design for a chair is narrowed by its claim language and title “Pattern for a Chair.”
The Court rejected Curver’s argument that the lower court wrongly relied on claim language reciting a “pattern for a chair,” instead of focusing on the patent illustrations, which lacked any illustrations of a chair.
Curver alleged that Home Expressions made and sold baskets with an overlapping “Y” design that infringed its design patent. The Federal Circuit found that Curver’s patent on an ornamental design for a chair is narrowed by its claim language and title “Pattern for a Chair.”
The Court rejected Curver’s argument that the lower court wrongly relied on claim language reciting a “pattern for a chair,” instead of focusing on the patent illustrations, which lacked any illustrations of a chair.