## Facts

- Apex owned three related patents (U.S. Patent Nos. 5,884,096; 5,937,176; 6,112,264) directed to KVM switching systems that let users control multiple remote servers from centralized workstations.
- The disclosed systems use signal-conditioning “pods” near user devices and servers, linked to a programmable central crosspoint switch that routes keyboard and mouse signals.
- Raritan sold competing KVM switching products (including MasterConsole and Paragon lines) that Apex accused of infringing the asserted patent claims.
- Apex sued Raritan for patent infringement in the Southern District of New York.
- The district court construed key claim terms (including terms like “standard keyboard” and “standard mouse”) and entered final judgment of noninfringement for Raritan; Raritan’s counterclaims were dismissed without prejudice.
- Apex appealed, arguing the district court’s claim constructions were legally incorrect and drove the noninfringement result.

## Issues

1. Whether the district court improperly narrowed the asserted claims by importing limitations from preferred embodiments in the specification.
2. Whether the district court improperly relied on the prosecution history to narrow claim scope without a clear and unmistakable disclaimer.
3. Whether terms such as “standard keyboard” and “standard mouse” should be construed as general conventional devices in the art rather than limited to particular historical interfaces or implementations.

## Decision

- The Federal Circuit vacated the district court’s judgment of noninfringement and remanded for further proceedings.
- The court held the district court erred as a matter of law in construing disputed claim limitations.
- The court rejected constructions that treated features described in particular embodiments as mandatory claim requirements without clear limiting language.
- The court concluded the prosecution history did not support the narrow constructions because it lacked a clear and unmistakable surrender of claim scope.
- Because the noninfringement judgment rested on erroneous constructions, infringement had to be reconsidered on remand under corrected constructions.

## Legal Principles

- Claim terms are generally given their ordinary and customary meaning as understood by a person of ordinary skill in the art, unless the patentee clearly acted as its own lexicographer or clearly disclaimed scope.
- The specification is an important guide to meaning, but courts may not read limitations from preferred embodiments into the claims absent clear intent to limit.
- Prosecution history can inform meaning, but narrowing based on prosecution statements requires a clear and unmistakable disclaimer; ambiguous or contextual arguments do not justify broad surrender.
- Terms describing “standard” components in computer-related claims are not confined to a single interface or implementation unless the intrinsic record clearly imposes that restriction.

## Conclusion

The Federal Circuit set aside a noninfringement judgment after determining that the district court’s claim constructions were too narrow, relying on embodiment details and an overreading of prosecution history; the case was remanded for infringement analysis under properly construed claims.


Apex Inc. v. Raritan Computer, Inc., 325 F.3d 1364 (Fed. Cir. 2003)