This is part of a series of articles discussing recent orders of interest issued in patent cases by the United States District Court for the District of Massachusetts.
In Dynocom Industries Inc. v. Magicmotorsport
S.R.I., No. 1:23-cv-12648, Judge Saris issued a claim
construction order. The parties reached agreement on several claim
terms and two terms remained in dispute.
The first concerned the meaning of “outwardly extending support arm.” The Court rejected both sides' proposed constructions as improperly seeking to import limitations from the specification into the claims and construed the term as “support arm capable of extending outward from the frame.”
The second disputed term was “secured to.” The Court began by observing that the first portion of the Parties' respective constructions – “connected to” and “fixed or attached to” were agreed to be essentially synonymous. The Court next observed that “secured to” is not a term of art or “used idiosyncratically” in the asserted patent and so looked to general purpose dictionaries. The Court declined to adopt a portion of one Party's construction that was mere surplusage. Last, the Court focused on the key dispute, finding that “secured to” does not require that the two secured objects are touching. In so doing the Court observed that in common usage one may “secure a bike to a tree” using a lock where the bike and tree are not actually touching and identified a disclosed embodiment where two objects are secured via an intervening part. Accordingly, the Court construed “secured to” as “fixed or attached to.”
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