Case: Patents/Claim Construction (Fed. Cir.)

The Federal Circuit vacated and remanded the decision of a federal district court in California granting Feit Electric Co. Inc. summary judgment on CAO Lighting Inc.'s action for infringement of a patent that concerns a semiconductor light source that can illuminate a space and efficiently dissipate heat. The appeals court determined that the judgment of non-infringement is based on an improper construction requiring the recited first reflective layer to be anepitaxial layer, and that the district court erred in requiring the first reflective layer and the substrate to be composed of different materials.