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Markman v. Westview Instruments, Inc.

Supreme Court of the United States · 1996 · Civil Procedure

Civil ProcedureSeventh AmendmentPatent claim constructionSeventh Amendmentjury trialquestion of lawquestion of factpatent

Facts

Markman owned a patent for an inventory control and reporting system for dry-cleaning stores. He sued Westview for infringement, and part of the dispute turned on the meaning of the term "inventory" in claim 1 of the patent. The jury heard testimony, including testimony from Markman's witness about the claim language, and found infringement of claims 1 and 10. The District Court then construed "inventory" to include both cash inventory and actual physical inventory of clothing, concluded Westview's system could not track clothing throughout the cleaning process as required under that construction, and entered judgment as a matter of law for Westview.

Issue

Whether interpretation of a patent claim, including disputed terms of art supported by expert testimony, is reserved entirely for the court or instead subject to the Seventh Amendment right to a jury determination. More specifically, the Court considered whether the meaning of the term "inventory" had to be decided by the jury.

Rule

The construction of a patent, including terms of art within its claim, is exclusively within the province of the court. The Seventh Amendment does not require that a jury determine the meaning of disputed patent claim language, even when expert testimony is offered.

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Nora Patel sues Lakefront Systems, Inc. in federal court in Chicago for patent infringement. The parties sharply dispute the meaning of the claim term "synchronizing node," and each side offers engineers to explain how that term is used in the field.

Who should decide the meaning of "synchronizing node"?

Explanation. The majority held that construction of a patent, including terms of art within its claims, is exclusively within the province of the court. The Seventh Amendment does not require a jury to determine the meaning of disputed patent language merely because expert testimony is offered. Patent infringement as a cause of action may carry a jury right, but claim construction itself is allocated to the judge.