Wenger Manufacturing, Inc. v. Coating MacHinery Systems, Inc. And Vector Corporation

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• finding that because dependent claim is limited to \recirculation\ of air, independent claim included device that either circulated or recirculated air
• refusing to consider a reference that was not evidence before the trial court and not part of the record on appea|
• refusing to consider a reference that was not evidence before the district court and not part of the record on appeal
• noting that the doctrine of “[c]laim differentiation ... is clearly applicable when there is a dispute over whether a limitation found in a dependent claim should be read into an independent claim, and that limitation is the only meaningful difference between the two claims”
• \[A] court may not import functional limitations that are not recited in the claim....\
• “[T]he doctrine of prosecution history estoppel is irrelevant to the determination of literal claim scope.” (internal quotation marks omitted)

Source: CourtListener parenthetical corpus (CC0).