CAFC reverses PTAB on BRI in CUTSFORTH, INC. v. MOTIVEPOWER

The CAFC said:


While claims are given their broadest reasonable interpretation [BRI]
in IPR proceedings, claim interpretation still
“must be reasonable in light of the claims and specification.”
PPC Broadband, Inc. v. Corning Optical Commc’ns
RF, LLC, --- F.3d ---, No. 2015-1364, 2016 WL 692369, at
*5 (Fed. Cir. Feb. 22, 2016). The Board’s interpretation of
“a projection extending from the mounting block” far
exceeds the scope of its plain meaning and is not justified
by the specification. We hold that the Board’s interpretation,
which encompasses a structure that recedes into the
mounting block rather than jutting out from it, is unreasonable.



Conclusion


For the foregoing reasons, we reverse the Board’s determination
that claims 14, 16-19, and 21-22 of the ’906
patent are anticipated by each of the Ohmstedt and
Krulls references. Because anticipation was the only
ground upon which the IPR was instituted as to these
claims, there are no remaining issues that warrant a
remand.