CCS Fitness, Inc. v. Brunswick Corporation, 288 F.3d 1359 (2002) Summary sbonomo

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This was a US Court of Appeals case, addressing a decision made by the US District Court for the District of Colorado. The case involved an elliptical fitness machine, specifically the "reciprocating member" of the machine that was claimed by CCS Fitness in its '333 patent. CCS accused Brunswick (Life Fitness) of infringing upon its claim. Life Fitness argued that CCS never specifically stated what all was meant by "member" in its claims, and that the drawings in the patent application only suggested a single straight member as comprising the reciprocating component. Since theirs was curved and contained multiple components, Life argued, it did not infringe upon the patent. The District Court agreed and ruled for summary judgment. Upon appeal, the Court of Appeals reversed the decision in part, based on the District Court's error in constructing the term "reciprocating member." The Court of Appeals relied on dictionary definitions and intrinsic evidence for its construction of the term, and determined that nothing restricted the term member from comprising of multiple components or being of a different shape. It also said that the drawings in the patent merely represented a particular embodiment of what was being patented, and thus the invention was not limited to what was illustrated.