Interpretations that render some portion of the claim language superfluous are disfavored. Here, for example, the claimed “pressurized collection vessel” was found to require an accumulation of material rather than just receiving material in a series of pipes and heat exchangers as in the accused system because to find otherwise would obviate the import of the word “collection.” “A claim construction that gives meaning to all the terms of the claim is preferred over one that does not do so.” It may therefore be best to avoid using potentially redundant or otherwise superfluous words in the claims whenever possible.
Background / Facts: The patent being asserted here is directed to an extrusion process that generates low viscosity aqueous polymer dispersions. The claims recite a “pressurized collection vessel” to prevent boiling and thus achieve a uniform polymer distribution. Meanwhile, the accused system utilizes a series of pipes and heat exchangers.
Issue(s): Whether the claimed “pressurized collection vessel” should be construed as requiring an accumulation, rather than simply receiving a flow of material as in the pipes and heat exchangers of the accused system.
Holding(s): Yes. “[A]dopting [the patentee’s] proffered construction of ‘gather or receive’ would ‘obviate[] the import of the word ‘collection.’’ [] There is no dispute that the ‘pressurized collection vessel’ receives the dispersion; that function is clearly contemplated by the surrounding claim language. [] But allowing ‘collection’ to mean ‘receive’ would render ‘collection’ entirely superfluous and allow any pressurized vessel to constitute a ‘pressurized collection vessel’; such a result is disfavored. [] The district court’s construction of ‘accumulation,’ on the other hand, gives the term ‘collection’ proper meaning in context.”