Seabed Geosolutions (US) Inc. v. Magseis FF LLC, No. 20-1237 (Fed. Cir. 2021)
Annotate this CaseThe 268 patent is directed to seismometers for use in seismic exploration, which generally involves sending an acoustic signal into the earth and using seismic receivers called geophones to detect “seismic reflections” from subsurface structures. Every independent claim of the patent recites, a “geophone internally fixed within” either a “housing” or an “internal compartment” of a seismometer. After being sued for patent infringement, Seabed petitioned for inter partes review of the 268 patent on multiple grounds. The Patent Trial and Appeal Board instituted review and found that the cited prior art did not disclose the geophone limitation and determined Seabed failed to prove the challenged claims were unpatentable. The Federal Circuit vacated. The intrinsic evidence consistently informs a skilled artisan that “fixed” in the claims means mounted or fastened. Given the clarity of the intrinsic evidence, resort to extrinsic evidence is unnecessary. The Board erred to the extent that it relied on extrinsic evidence to alter the meaning of “fixed,” which is clear from the intrinsic evidence.
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