The Court of Appeals for the Federal Circuit, in Edgewell Personal Care Brands, LLC et al. v. Munchkin, Inc., No. 2020-1203 (Fed. Cir. March 9, 2021), reversed the district courts grant of summary judgment because the district court incorrectly construed the term “clearance” based on how the claimed apparatus was used, and not what the apparatus was. The Court ruled that the “clearance” limitation was satisfied when the apparatus itself is constructed with a clearance. Further, “annular cover” and “tear-off section” were correctly construed based on the written description as being part of a single structure. However, the district court incorrectly relied on claim vitiation stemming from this construction to grant summary judgment under the DOE, instead of evaluating evidence under the function-way-result test.
The full opinion is here: http://www.cafc.uscourts.gov/sites/default/files/opinions-orders/20-1203.OPINION.3-9-2021_1745042.pdf