Markman v. Westview Instruments, Inc. - Case Brief
Markman v. Westview Instruments, Inc., 517 U.S. 370 (1996).
Facts:
Markman obtained a patent for a system of monitoring clothes through the dry-cleaning process. The system included generating and attaching a bar code that could be read by optical detectors to each item of clothing. According to the claim at issue, the invention can “maintain an inventory level” and “detect and localize spurious additions to inventory.” The jury heard an expert witness testify regarding the claim’s meaning and found that Westview had infringed Markman’s patent. The trial court nevertheless entered a directed verdict for Westview, stating that the accused device did not track inventory within the meaning of Markman’s claim. The Court of Appeals affirmed and held that claim interpretation is a matter of law and therefore a matter to be decided by the court and not the jury.
Issue: Is claim interpretation a matter of fact to be decided by the finder of fact, or a matter of law to be decided by the court?
Holding:
Claim construction is a matter of law to be decided by the court. The Seventh Amendment right to trial by jury is to be defined according the right under English common law when the Amendment was adopted. The court held that infringement cases at common law were decided by juries. Terms in the specifications however were interpreted by the judge. This case has led to the practice of holding “Markman hearings” in which the court will hear testimony and receive evidence prior to trial in order to determine interpret the scope of the claims at issue.
Disposition: Affirmed
Argued: January 8, 1996
Decided: April 23, 1996
Majority by: Souter
Joined by: Unanimous