Terms Susceptible to Their Ordinary Meaning are Not Means Plus Function

Kolcraft Enters., Inc. v. Artsana USA, Inc. d/b/a Chico USA, Inc., No. 13 C 4863, Slip Op. (N.D. Ill. Nov. 14, 2017) (Ellis, J.). Judge Ellis construed the claims in this patent dispute involving infant play gyms. Of particular note, the Court held as follows: No construction was necessary for — connector(s); to couple; fastener(s); first fastener; positionable; and several other connector-related phrases. The Court construed “pivotally coupled” to mean “each connector is linked, connected or fastened to the floor mat by a fixed pivot element, such as a shaft or pin, about which the connector pin turns, rotates or moves about. A pivot coupling is different than a coupling that is fixed.” The parties agreed as to the first clause. The Court imported the remainder of the limitation from plaintiff’s statements during a related Inter Partes Review regarding coupling. The first and second connector terms did not require construction and were not…

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