Computer Docking Station Corp. v. Dell, Inc.
United States Court of Appeals for the Federal Circuit
519 F.3d 1366 (2008)
Computer Docking Station Corp. (CDSC) (plaintiff) held a patent on a "brick" computer lacking a built-in display or keyboard, connectable to external peripherals through docking connectors; during patent prosecution, to overcome a rejection based on a prior laptop-and-docking-module patent (Herron), CDSC characterized its invention in terms that excluded laptops with built-in displays and keyboards. CDSC sued Dell and others (defendants) for infringement based on portable computers that did have built-in displays and keyboards; the district court granted summary judgment for Dell, and CDSC appealed.
Whether a patentee may limit the meaning of a claim term by making a clear and unmistakable disavowal of scope during patent prosecution.