Although limitations from the specification should not ordinarily be imported into the claims, “the embodiments define the outer limits of the claim term.” Thus, when a certain feature is present in all the embodiments and touted as advantageous, it may be reasonably read into the interpretation of any related claim terms. Claims written more broadly should be supported with a wider variety of examples when drafting the specification.
Background / Facts: The patents being asserted here are directed to “data mediation software,” which collects, processes, and compiles network records so that network usage can be tracked and billed appropriately. In this regard, the claims recite the use of components configured to “enhance” a network accounting record. Although the plain meaning of “enhance” does not require a particular location for or configuration of the component performing the enhancement, the specification repeatedly refers to a “distributed” set of components as the sites of the enhancement and touts their efficiencies as compared to a more centralized system.
Issue(s): Whether including the limitation “in a distributed fashion” in the construction of “enhance” is an impermissible importation of limitations from the specification into the claims.
Holding(s): No. “The chief problem with [the patentee’s] position [advocating a broader construction] is that there is no suggestion within the specification of centralized, as opposed to distributed, enhancement.” Moreover and to the contrary, “as both the district court and [accused infringer] point out, the specification repeatedly recites the advantages of distributed enhancement. For example, the specification states that, ‘[i]mportantly, the distributed data gathering, filtering, and enhancements performed in the system enables load distribution.’ … The district court properly concluded that the embodiments define the outer limits of the claim term and did not err in reading the ‘in a distributed fashion’ and the ‘close to the source’ of network information requirements into the term ‘enhance.’”