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Likely success not shown where the district court relied on erroneous claim construction

Likely success not shown where the district court relied on erroneous claim construction

Chamberlain v. Techtronic is a nonprecedential case decided on January 25, 2017 on appeal from the Northern District of Illinois. There, the district court granted plaintiff Chamberlain a preliminary injunction, finding that Chamberlain had shown a substantial likelihood of success on the merits of its infringement claim. Techtronic appealed.

The Federal Circuit vacated the grant of the preliminary injunction.

To show entitlement to a preliminary injunction, the patentee must show that it is likely to succeed on the merits. Where the accused infringer raises a “substantial question concerning validity, enforceability, or infringement,” the preliminary injunction should not issue. The patentee rebuts the accused infringer’s defense by showing it “lacks substantial merit.” A district court’s grant of a preliminary injunction is reviewed for abuse of discretion.

The Federal Circuit held that the district court erred in finding that Chamberlain would likely succeed on the merits. The district court’s finding was based on an erroneous claim construction. And this erroneous construction “was the court’s sole basis for determining that [Techtronic] had not raised a substantial question of validity.” Because the construction was incorrect, the Federal Circuit vacated the grant of the preliminary injunction.

 

Chamberlain Grp., Inc. v. Techtronic Indus. Co., 676 F. App’x 980 (Fed. Cir. 2017)

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