Case 27: CCS Fitness, Inc. v. Brunswick Corporation (2002)
The CAFC heard a case in which Life Fitness, a division of Brunswick, was accused of infringing a patent held by CCS Fitness for an elliptical trainer. The CCS patent claimed a "reciprocating member," which the District Court in Colorado held applied only to a straight, unibody arm. Life Fitness' design incorporated a multiple-component, curved bar, which warranted summary judgment of noninfringement. Because the term "member" does not in itself exclude the use of a multi-component curved bar, and the patent claims do nothing to narrow the definition of the term, the CAFC overruled the District's ruling and remanded the case for further judgment. The District Court concluded that while the patent didn't specifically claim a straight bar only, it also did not specifically include curved, multibody arms, either; in fact, the patent illustrations depict a straight bar. However, the CAFC concluded that the connecting arms were essentially the same under the doctrine of equivalents. The reciprocating member in both machines performs the same function; thus, they are intrinsically the same feature. The CAFC says that infringement is a two-step process:
- The correct meaning and scope of the disputed term is determined by the court;
- The claims are compared to the accused device to determine whether the device exhibits all of the limitations of the claimed invention, whether literal or by equivalents.
Because Life Fitness could not prove that "member" was ambiguous enough not to include its component, the ruling is reversed. The ruling that "reciprocating member" did not pertain to the doctrine of equivalents is vacated, and the case remanded to determine infringement.
