PPC Broadband, Inc. v. Corning Optical Communications RF, LLC
United States Court of Appeals for the Federal Circuit
815 F.3d 747 (2016)
PPC's (defendant) coaxial-cable-connector patent claimed a "continuity member" positioned to "reside around" an external portion of the connector; during Corning's (plaintiff) inter partes review challenge, the Patent Board used a general dictionary to define "reside around" as merely "in the immediate vicinity of," reasoning that because PPC used the word "surrounded" elsewhere in the claim's preamble, "reside around" must mean something different, and on that basis found the claims obvious over prior art. PPC appealed, arguing the broadest reasonable construction of "reside around," read in light of the specification, was actually "encircle or surround."
Whether it is sufficient to rely solely on a dictionary definition of a patent claim term when determining the claim's broadest reasonable interpretation consistent with the specification.