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MTD Products Inc. v. Iancu

United States Court of Appeals, Federal Circuit

August 12, 2019

MTD PRODUCTS INC., Appellant
v.
ANDREI IANCU, UNDER SECRETARY OF COMMERCE FOR INTELLECTUAL PROPERTY AND DIRECTOR OF THE UNITED STATES PATENT AND TRADEMARK OFFICE, Intervenor

          Appeal from the United States Patent and Trademark Office, Patent Trial and Appeal Board in No. IPR2016-00194.

          John Salvatore Cipolla, Calfee, Halter & Griswold LLP, Cleveland, OH, argued for appellant. Also represented by Andrew Alexander, Tracy Scott Johnson, Mark McDougall.

          Peter John Sawert, Office of the Solicitor, United States Patent and Trademark Office, Alexandria, VA, argued for intervenor. Also represented by Thomas W. Krause, Philip J. Warrick.

          Before Reyna, Taranto, and Stoll, Circuit Judges.

          Stoll, Circuit Judge.

         The Toro Company sought inter partes review of claims 1-16 of U.S. Patent No. 8, 011, 458 before the U.S. Patent and Trademark Office's Patent Trial and Appeal Board. The Board instituted review and, in its final written decision, held the challenged claims obvious under 35 U.S.C. § 103. Critical to its decision, the Board determined that the claim term "mechanical control assembly . . . configured to" perform certain functions is not a means-plus-function term subject to 35 U.S.C. § 112, ¶ 6. MTD Products Inc., owner of the '458 patent, appeals the Board's decision.

         We conclude that the Board erred by conflating corresponding structure in the specification with a structural definition for the term, and by misinterpreting certain statements in the prosecution history. Under the appropriate legal framework, we conclude that the term "mechanical control assembly" is a means-plus-function term governed by § 112, ¶ 6. We therefore vacate the Board's obviousness conclusion, which was predicated on its incorrect claim construction, and remand for further proceedings consistent with this opinion. Because we are persuaded by MTD's primary argument, we do not reach its alternative arguments.

         Background

         I

         The '458 patent discloses a steering and driving system for zero turn radius ("ZTR") vehicles, with specific reference to ZTR lawn mowers. '458 patent col. 1 ll. 17-21. The patented system is designed to provide a more intuitive steering mechanism to operators of ZTR vehicles. Id. at col. 1 ll. 20-38. In contrast to prior art systems that reverse in the opposite direction of a forward motion turn, the claimed invention permits ZTR vehicles to turn in the same direction both forward and backwards. Id. at col. 1 ll. 20-47. The claimed steering mechanism thus mimics the forward and backward movements of an automobile.

         The term "mechanical control assembly" appears in both claims 1 and 9, the only independent claims of the '458 patent. Claim 1 recites:

1. A vehicle capable of making a small radius turn, comprising:
a frame;
a left drive wheel and a right drive wheel, both coupled to the frame;
two independent left and right drive units, the left drive unit coupled to the left drive wheel via an axle and the right drive unit coupled to the right drive wheel via another axle;
a steering device coupled to the frame;
a speed control member coupled to the ...

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