All words of a claim term must be given meaning. Here, for example, the term “display format” referring to a video signal was found to require that the video signal be “ready for use” by a conventional external monitor in order to give meaning to the word “display” as differentiated from other types of formats. “[An alternate] construction would essentially read the word [at issue] out of the term and is inconsistent with the surrounding limitations of the asserted claims.” It may therefore be best to ensure that claim terminology is as concise as is feasible, and avoid any extraneous terms that may impart separate and additional meaning.
Background / Facts: The patents being asserted here are directed to a device that converts compressed video content received by a mobile phone from a wireless network into a video signal format ready for display on a larger external display such as a television. The parties agree that a video signal that is decompressed/uncompressed is a necessary feature of the claimed “display format.”
Issue(s): Whether the claimed “display format” further requires a video signal that is “ready for use” by a conventional external monitor.
Holding(s): Yes. “The limitations of the asserted claims suggest that a ‘display format’ is more than an uncompressed video signal. In particular, the wording of ‘display format’ itself suggests that a ‘display format’ is not just any uncompressed video signal, but a signal in a format that—per the claims—‘accommodate[s]’ the display of video content on an external monitor. Further, the claims recite that a ‘signal conversion module’ not only decompresses the received compressed video signal, but also converts that signal to a specific video signal comprising ‘a display format for the [external monitor]’ and ‘a power level appropriate for driving the [external monitor].’ [] [The patentee’s] desired construction would essentially read the word ‘display’ out of the term and is inconsistent with the surrounding limitations of the asserted claims.”