Federal Circuit Reverses District Court’s Narrow Claim Construction Ruling
Tuesday, January 25, 2022
Federal Circuit In Evolusion Concepts, Inc. v. HOC Events Ruling

In Evolusion Concepts, Inc. v. HOC Events, Inc., No. 2021-1963 (Fed. Cir. Jan. 14, 2022), the Federal Circuit reversed and vacated the district court’s summary judgment rulings and the award of attorney’s fees.

The patent-in-suit is directed to a device for converting a rifle with a detachable magazine to one with a fixed magazine. In granting Juggernaut’s motion for summary judgment of non-infringement, the district court construed “magazine catch bar” to exclude a factory-installed bar. The district court based its construction on an embodiment disclosing “removing the standard OEM magazine catch assembly and installing the invention,” and an unasserted claim reciting a method of removing the factory-installed magazine catch bar and installing a magazine catch bar.

The Federal Circuit reversed, holding that “magazine catch bar” does not exclude a factory-installed bar. The Federal Circuit noted that the unasserted claim requires only removing a specific type of bar and then installing “a magazine catch bar”—which could either be the removed bar or a different bar, and the specification does not limit the scope of a “magazine catch bar” to exclude factory-installed bars. The Federal Circuit also vacated the award of attorney’s fees because Juggernaut is no longer a prevailing party.

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