## Facts

- Prior golf-club designs followed established clubhead profiles and used calibrated amounts of metal or graphite based on a golfer’s characteristics.
- Nassau Precision Casting Co., Inc. (Nassau) owned U.S. Patent No. 5,486,000, which claimed methods relating to a weighted golf iron club head with redistributed mass intended to improve ball-striking performance while keeping overall clubhead weight the same.
- The patent’s approach involved removing construction material from certain upper portions of the clubhead—described as portions not used in ball striking—and relocating that removed material to lower “clearance” positions on the underside of the clubhead.
- Nassau sued Acushnet Co., Inc. and related entities for infringing claims 1 and 2 of the ’000 patent based on certain Cobra-brand irons.
- In construing claim 2, the district court treated it as describing Nassau’s method for keeping the post-redistribution clubhead weight equal to the original weight by using only metal or graphite material; it held Acushnet did not infringe because Acushnet used polymer material in its design.
- In construing claim 1, the district court addressed language about removing material from a “location not used during ball-striking service” and rejected Nassau’s view that parts of the face could be excluded from ball striking; the court reasoned a golfer might hit a ball with any part of the face, even inadvertently.
- The district court nonetheless granted summary judgment of noninfringement on claim 1 because it read the claim as requiring removal of material from portions of both the clubhead’s face and its top, while the accused clubheads removed material only from the top surface and left the face intact.
- The district court also rejected Acushnet’s argument that the asserted “method” claims were limited to a manufacturing process and therefore could not be infringed by Acushnet’s design activities.
- Nassau appealed the summary judgment of noninfringement to the Federal Circuit.

## Issues

1. Whether summary judgment of noninfringement on claim 2 was proper where the accused clubheads maintained weight using polymer and the claim required the removed construction material or weight to be embodied in specified lower regions while maintaining the same overall clubhead weight.
2. Whether the district court’s summary judgment of noninfringement on claim 1 was proper in light of the claim language requiring removal of material from a “location not used during ball-striking service,” given that the accused products removed material from the top surface (not the face).
3. Whether the asserted “method” claims should be limited to manufacturing steps, as Acushnet argued, or instead could cover a method implemented through design choices reflected in the finished clubhead.

## Decision

- The Federal Circuit affirmed summary judgment of noninfringement as to claim 2.
- The Federal Circuit vacated summary judgment of noninfringement as to claim 1 and remanded for further proceedings.
- For claim 2, the court concluded that, on the undisputed record and the requirements of the claim, the accused clubheads did not meet the limitation tying the removed construction material or weight to specified lower locations while maintaining the overall clubhead weight.
- For claim 1, the court held the district court’s reasoning could not support summary judgment: under the district court’s own approach to “used during ball-striking service” (treating the face as the ball-striking area), removing material from the top surface would satisfy the “location not used during ball-striking service” limitation rather than defeat it.
- The Federal Circuit rejected Acushnet’s attempt to confine “method” to manufacturing-only activity, concluding the claim term “method” was not restricted to physical fabrication steps by the intrinsic record.

## Legal Principles

- Claim terms are construed in view of the claim language and the specification; limitations should not be added without support in the intrinsic record.
- “Method” claims are not automatically limited to manufacturing processes; absent a clear disclaimer or definitional limitation, “method” may cover a sequence of actions reflected in design choices and outcomes.
- Summary judgment of noninfringement is proper only when, under the correct construction and undisputed facts, no reasonable factfinder could find infringement.
- A noninfringement ruling cannot rest on an internal inconsistency in the court’s own claim analysis; the infringement analysis must follow from the adopted construction and the undisputed product features.

## Conclusion

In this nonprecedential Federal Circuit decision, the court affirmed noninfringement of claim 2 of Nassau’s golf-club patent because the undisputed evidence did not satisfy the claim’s requirements for how removed material or weight must be embodied in specified lower regions while maintaining overall weight. But it vacated summary judgment on claim 1 because the district court’s reasoning, as applied to the accused clubheads that removed material only from the top surface, did not logically support a finding of noninfringement under the court’s own understanding of what locations are “used during ball-striking service,” and it remanded for further proceedings.


Nassau Precision Casting Co., Inc. v. Acushnet Co. Inc., 566 Fed. Appx. 933 (2014)