Kolcraft Enters., Inc. v. Artsana USA, Inc. d/b/a Chico USA, Inc., No. 13 C 4863, Slip Op. (N.D. Ill. Nov. 14, 2017) (Ellis, J.).

Judge Ellis construed the claims in this patent dispute involving infant play gyms.

Of particular note, the Court held as follows:

  • No construction was necessary for — connector(s); to couple; fastener(s); first fastener; positionable; and several other connector-related phrases.
  • The Court construed “pivotally coupled” to mean “each connector is linked, connected or fastened to the floor mat by a fixed pivot element, such as a shaft or pin, about which the connector pin turns, rotates or moves about. A pivot coupling is different than a coupling that is fixed.” The parties agreed as to the first clause. The Court imported the remainder of the limitation from plaintiff’s statements during a related Inter Partes Review regarding coupling.
  • The first and second connector terms did not require construction and were not means plus function terms. The Court did hold that the first connectors and second connectors must be distinct from each other, but not necessarily separate.
  • The Court construed “movable coupled” to mean “each leg of the play gym can be moved relative to the hub while the first end of each leg is linked, connected, or fastened to the hub.”
  • The Court construed “play gym” to mean “a structure or apparatus which is capable of suspending an object over a defined area.”