Catalina Marketing International v. Coolsavings.com, Inc.
United States Court of Appeals for the Federal Circuit
289 F.3d 801 (Fed. Cir. 2002)
Catalina (plaintiff) owned a patent for a system distributing discount coupons through kiosk-like terminals "located at predesignated sites such as consumer stores," and sued Coolsavings (defendant) for infringement based on its web-based coupon-printing service; Coolsavings argued the location language in the claim preambles was limiting, meaning its internet-based (rather than physical-kiosk) system fell outside the patent's scope, and the district court agreed, finding no infringement. Catalina appealed.
Whether a patent claim's preamble language describing the location of a claimed device is treated as a limiting element of the claim, restricting its scope to that specific location.