Absent clear redefinition or disavowal, the plain meaning of a claim limitation will be controlling over other descriptions in the specification when the plain meaning is unambiguous. Here, for example, a “query” concerning the online status of other network devices was found to be limited to certain real-time embodiments by the plain language of the claims reciting that the query seeks to determine whether a given device “is [present tense] connected to the computer network.” “When claim language has as plain a meaning on an issue as the language does here, leaving no genuine uncertainties on interpretive questions relevant to the case, it is particularly difficult to conclude that the specification reasonably supports a different meaning.” It may therefore be best to ensure that each claim limitation is drafted to be clear and accurate on its face without necessarily having to resort to the context provided by the specification.
Background / Facts: Facts: The patent on appeal here from rejection at the PTO during inter partes review proceedings is directed to a connection server for establishing communication links through the Internet that stores online status information for various devices. To reduce the staleness of the status information, the specification describes embodiments in which the server updates the status of each device periodically (e.g., every 2 hours) and other embodiments in which the devices inform the server in real-time when they intend to go offline. The claims recite a device checking the status information of another device by “transmitting, to the server, a query as to whether [the other device] is connected to [the] computer network.”
Issue(s): Whether the “query” claim language is generic to all embodiments such that the query need only request whatever the connection server has listed about a device’s online status, even if the listed information is not accurate at the time of the query, rather than being limited to the particular embodiments in which the information is updated in real-time.
Holding(s): No. “The present tense ‘is’ in ‘is connected to the computer network’ plainly says that the query transmitted to the server seeks to determine whether the second unit is connected at that time, i.e., connected at the time that the query is sent. The question asked by the query is whether the device ‘is’ connected, not whether it was connected or whether it is still registered as being connected even if that registration information is no longer accurate. It is not a reasonable interpretation of the claim language, considering its plain meaning, to say that it is satisfied by a query that asks only for registration information, regardless of its current accuracy.”