Deere & Co. v. Bush Hog, L.L.C.

Plaintiff’s patent discloses an “easy clean dual wall deck” for a rotary cutter. Defendants manufacture rotary cutters that are pulled behind a tractor and used to mow wide swaths of ground. The accused rotary cutters can “rough cut” fields after a harvest or clear weeds and brush along roadsides. Plaintiff’s patent addresses a problem encountered by rotary cutters. Prior art cutters had structural components such as gearboxes and deck bracings mounted either on top of or underneath the cutter deck; the patent discloses a dual-wall deck that encloses the structural components in a torsionally-strong box, leaving smooth surfaces on the top and bottom of the deck for easing cleaning. The district court entered summary judgment of noninfringement. The Federal Circuit vacated, affirming the construction of “rotary cutter deck” and the determination that the terms “substantially planar” and “easily washed off” do not render the asserted claims invalid under 35 U.S.C. 112, but holding that the district court erroneously construed the term “into engagement with” to require direct contact. View "Deere & Co. v. Bush Hog, L.L.C." on Justia Law