MTD Products Inc. v. Iancu, No. 17-2292 (Fed. Cir. 2019)Annotate this Case
MTD’s 458 patent discloses a steering and driving system for zero-turn radius (ZTR) vehicles, with specific reference to ZTR lawnmowers. The patented system is designed to provide a more intuitive steering mechanism to operators of ZTR vehicles. Toro sought inter partes review of claims 1–16 of the patent. The U.S. Patent and Trademark Office’s Patent Trial and Appeal Board found the challenged claims obvious under 35 U.S.C. 103, holding that the claim term “mechanical control assembly . . . configured to” perform certain functions is not a means-plus-function term subject to 35 U.S.C. 112. The Federal Circuit vacated, concluding that the Board erred by conflating corresponding structure in the specification with a structural definition for the term, and by misinterpreting certain statements in the prosecution history. Under the appropriate legal framework, the term “mechanical control assembly” is a means-plus-function term governed by section 112. That the specification discloses a structure corresponding to an asserted means-plus-function claim term does not necessarily mean that the claim term is understood by persons of ordinary skill in the art to connote a specific structure or a class of structures.