Court Will Not Import Limitations From the Specification

Morningware, Inc. v. Hearthware Home Prods., Inc., No. 09 C 4348, Slip Op. (N.D. Ill. Feb. 23, 2011) (St. Eve, J.). Judge St. Eve construed the the claims of counter-plaintiff Hearthware's patent involving halogen convection ovens. Of particular note, the Court construed the following terms: "A cooking enclosure" means "an oven housing and a metallic oven pan supported by a base." This definition fit with the language of the abstract and the summary of the invention. "A fan" means "one or more fans." The Court declined Morningware's argument that fan be limited to the fan described in the preferred embodiment. "A fan chamber" means "one or more enclosed spaces, through which a fan moves air, that are in the power head and above both the cooking enclosure and the heating unit." The Court held that a more particular definition proposed by Morningware would require improper importation of limitations into the claims from the specification.

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