IP Innovation v. eCollege: Dist Ct claim construction upheld, plaintiff loses
For the second step of the infringement analysis, the CAFC cited N.Am. Container v. Plastipak, 415 F.3d 1335.
Of claim construction, the quote (bedrock principle...) found in Innova, 381 F.3d 1111 reproduced in Phillips, is cited. I cited Innova myself in discussing Quillen/Webster, who ignored the bedrock principle in their analysis of patent grant rates.