Interactive Fitness Holdings, LLC v. Icon Health & Fitness, Inc.

When a patent differs from prior art by only a single limitation, the patent is invalid by anticipation if that limitation is covered by other prior art.

Opinion (Benson): Icon sued Interactive, alleging infringement of its ‘424, patent, which described a display system for exercise equipment. Icon owned the patent by assignment. Both parties moved for summary judgment on the question of infringement, and Interactive moved for summary judgment for invalidity. During the application process, the PTO rejected the application as anticipated by a prior patent. To overcome the rejection, the applicants amended several claims by adding a “topographical representation” limitation. The PTO accepted the amended application and issued the patent. Because the patent's prosecution history did not indicate that the applicants intended the term to have a special meaning, the Court construed the term according to its plain meaning as “[a] graphic representation of the surface features of a place or region, indicating their relative positions and elevations.” The Court held that Interactive's devices did not infringe the patent, because its devices did not display relative position information. On invalidity, Interactive argued that an earlier patent describing an exercise bike that displayed “a topographical representation of a virtual trail” anticipated Icon’s patent. Because the Court found that the prior patent “clearly [met] the requirements of a topographical representation,” it held Icon's patent INVALID by anticipation.