INTIRTOOL, LTD. (doing business as MASS-TEX, Ltd.), Plaintiff-Appellant, v. TEXAR CORPORATION (doing business as ToolPro, Inc.), Defendant-Appellee., 369 F.3d 1289

Summary

The patent was directed to punch pliers used with sheet metal. The manufacturer contended that the tools sold by defendant tool distributor infringed the manufacturer's patent. The district court construed the "hand-held punch pliers for simultaneously punching and connecting overlapping sheet metal" of the claim preamble as a limitation of the claim. After finding that the pliers punched holes in overlapped sheets but did not connect the sheets, the district court found that the patent did not contain an adequate description of the claimed invention. The court, however, held that the preamble was not a limitation because it added nothing to the highly detailed claim and, thus, could not be considered to give "life, meaning, and vitality" to the claim. The district court's error in construing the preamble as a limitation rendered its written description finding clearly erroneous and its inequitable conduct conclusion an abuse of discretion. The court also found that the district court ...