No Infringement Where Structural Difference Renders Claimed Function Impossible
Client Alert | 1 min read | 04.17.06
Despite affirming the district court's summary judgment of non-infringement in Semitool, Inc. v. Dynamic Micro Systems Semiconductor Equipment GmbH, (“DMS”) (No. 05-1299; April 6, 2006), the Federal Circuit finds the district court's claim construction flawed. The primary claim at issue relates to a semiconductor wafer carrier cleaning system and is directed to a process using “a processing chamber within the processing vessel” and furthermore “supplying drying gas to the processing chamber.” The district court granted a motion for summary judgment of non-infringement in favor of DMS, but concluded that it did not need to reach the issue of whether a “condensing unit” of the allegedly-infringing product was part of the process chamber or a separate unit. Instead, the district court focused on the function of whether the condenser supplied gas to the processing chamber. In contrast, the Federal Circuit reasons that, since the condenser of the allegedly-infringing product resides inside the processing chamber, it cannot supply the recited drying gas. Thus, the determinative claim language was the recited structure and not the function.
Insights
Client Alert | 3 min read | 01.20.26
DoW Joins SBA’s Fight Against Alleged Pass-Through Fraud in the 8(a) Program
On January 16, 2026, U.S. Secretary of War Pete Hegseth posted a video on social media outlining the U.S. Department of War’s (DoW) plan to combat fraud, waste, and abuse in the Small Business Administration’s (SBA) 8(a) Business Development Program.
Client Alert | 3 min read | 01.20.26
Federal Government Challenges Minnesota Law Requiring Affirmative Action in State Government
Client Alert | 1 min read | 01.20.26
Client Alert | 6 min read | 01.16.26
Trump Administration Rolls Out New DOJ Division for National Fraud Enforcement
