Skyline Zipline Global, LLC v. Domeck

A device that is the antithesis of a patented product does not infringe the original patent.

Opinion (Seabright): Skyline sued several companies (collectively, “Domeck”) alleging infringement of its ‘066 patent, which describes an improved zipline-trolly design. Domeck moved for summary judgment of non-infringement. The Court's opinion turned on the meaning of the term “spreader” in the only independent patent claim. Considering the plain meaning of the term “spreader,” the patent specification, and patent prosecution history, the Court construed the term to mean a device that holds two linear elements apart. Domeck’s devices contained a metal component that attached lines coming from the top of the trolley to lines attached to the handlebars. Skyline argued that this device was a “spreader” because it separated the two sets of lines. The Court, however, rejected that argument, because the device served to bring the two sets of lines together in a single point, rather than separate them. Because the accused component brought together (rather than held apart) the lines, the court held that the device was “the antithesis of a spreader” and, therefore, the Domeck had not infringed Skyline's patent under either theory. Summary judgment for Domeck was GRANTED.