Judge Andrews Issues Claim Construction for Patent Directed to Dynamic Logic Circuit Technology, Rejects Argument That Disputed Claim Terms Are Indefinite

In AVM Technologies, LLC v. Intel Corporation, C.A. No. 10-610-RGA, Judge Andrews recently issued a claim construction opinion construing claim terms for U.S. Patent No. 5,859,547 (“the ‘574 Patent”), which is a patent that claims “an improved dynamic logic circuit ‘that has increased speed and reduced power.’” Id. at 2 (citation omitted). In the opinion, the Court construed the following terms:

“coupled to”
“coupled between”
“couplable to”
“coupling”
“anti-float circuit”
“precharge node”
“dynamic logic circuit”
“dynamic logic block” or “logic block”
“evaluation transistor”
“precharge transistor”
“a delay”
“for simultaneous activating”
“during a major portion of the evaluation phase”
“during a major portion of an evaluation clock phase”
“during a minor portion of the evaluation clock phase”
In both its claim construction briefing and at the Markman hearing, defendant argued that: (a) the “during a major portion of the evaluation phase” language of claim 1 of the patent-in-suit and (b) the “during a major portion of an evaluation clock phase” and “during a minor portion of the evaluation clock phase” language of claim 21 of the patent-in-suit were “not amenable to construction” and thus, “indefinite and . . . invalid under 35 U.S.C. § 112, ¶ 2.” Id. at 13. The Court, however, rejected these arguments. Citing to the Federal Circuit’s decisions in Praxair v. ATMI, Inc., 543 F.3d 1306, 1319 (Fed. Cir. 2008) and Honeywell Int’l Inc. v Int’l Trade Comm’n, 341 F.3d 1332, 1338-39 (Fed. Cir. 2003), respectively, for the propositions that “the standard of indefiniteness is high” and that “a claim is indefinite only if the ‘claim is insolubly ambiguous, and no narrowing construction can properly be adopted,’” the Court held that these disputed terms were not indefinite and construed each of them. Id. at 13-15. This opinion is interesting because it provides some insight as to how the Court may handle indefiniteness arguments and other indefiniteness-related issues raised during claim construction.

AVM Technologies, LLC v. Intel Corporation, C.A. No. 10-610-RGA