## Facts

- Coleman owned U.S. Design Patent No. D623,714 claiming the ornamental design of a personal flotation device (PFD) depicted with two armbands connected to a torso piece, including a flat-back torso portion that tapers toward a connecting strap on the sides.
- Sport Dimension sold the Body Glove Model 325 PFD, also featuring two armbands connected to a torso portion, but with a torso section extending upward into a vest-like portion over the shoulders.
- Sport Dimension filed a declaratory-judgment action seeking findings of noninfringement and invalidity of the D’714 patent.
- The district court excluded Coleman’s proposed expert (an industrial designer) for lack of substantive experience in personal flotation device design.
- In claim construction, the district court treated certain design aspects as functional and effectively removed the armbands and side-tapering torso features from the claimed design when assessing infringement.
- Based on that construction, the parties stipulated to noninfringement, and the district court entered judgment to permit appellate review.

## Issues

1. Whether the district court abused its discretion by excluding Coleman’s design expert for insufficient product-specific qualifications.
2. Whether the district court erred in construing the design patent by eliminating design elements as functional, thereby narrowing the claim for infringement analysis.

## Decision

- The Federal Circuit affirmed the exclusion of Coleman’s expert, holding the district court acted within its discretion in finding the expert lacked relevant, product-specific experience.
- The Federal Circuit vacated the stipulated judgment of noninfringement because the district court’s claim construction improperly eliminated design features as functional.
- The case was remanded for further proceedings applying a claim-construction approach consistent with considering the design as shown in the drawings.

## Legal Principles

- A design patent claim is defined by the design as shown in the patent’s drawings.
- Design patents may include functional elements; the presence of functional aspects does not justify deleting entire structural features from the claimed design during claim construction.
- Infringement analysis may account for functionality by giving functional aspects less weight, but the overall visual impression must be assessed using the complete design rather than a truncated version.
- Trial courts have broad discretion to assess expert qualifications; general industrial design experience may be insufficient where opinions require familiarity with the specific product category.

## Conclusion

The Federal Circuit upheld the trial court’s exclusion of Coleman’s expert but vacated the noninfringement judgment because the design claim construction impermissibly excised purportedly functional elements, requiring reconsideration of infringement with the full design reflected in the drawings.


Sport Dimension, Inc. v. Coleman Co., 820 F.3d 1316 (Fed. Cir. 2016)