The plain meaning of “coupled to” excludes the relationship between simple sub-components and the larger component of which they are a part. Here, for example, a brush catch in the prior art that was part of a beam component was found to be patentably distinct from the claimed “brush catch coupled to [a] beam” because in the prior art the two elements were not separate components. “It goes beyond the plain meaning of ‘coupled’ to say that a sub-component (e.g., an engine in a car) is ‘coupled to’ the component as a whole (e.g., the car).” It may therefore be best to avoid claiming sub-components as being “coupled to” the larger component of which they are a part; conversely, this would be a good case to consult and cite in response to an examiner’s assertion that part of a given component can be considered as “coupled” thereto.
Background / Facts: The patent on appeal here from inter partes review proceedings at the PTO is directed to a removable brush holder assembly used in electric generators and motors. The invention makes it easier to remove and replace brushes during operation as the brushes wear down, which allows for safer and more cost effective maintenance. The claims recite “[a] brush catch coupled to [a] beam.”
Issue(s): Whether the “brush catch” may be a sub-component of the “beam” as in the prior art and still considered to be “coupled to the beam” as claimed.
Holding(s): No. “[T]he claims-at-issue require a ‘brush catch’ to be a physical structure that is separate from, and not a sub-component of, the claimed ‘beam.’ It goes beyond the plain meaning of ‘coupled’ to say that a sub-component (e.g., an engine in a car) is ‘coupled to’ the component as a whole (e.g., the car). No evidence shows that the inventors intended to deviate from the plain meaning of ‘coupled to.’”