The patents cover decorative lighting strings featuring bulbs spaced along a string that switch between a steady-on state and special visual effects such as pulsing, twinkling, or flashing.
The court held that the plain and ordinary meaning of each disputed term was controlling and did not require a specialized construction.
The court adopted the parties' agreed-upon definition of a person of ordinary skill in the art as an individual with at least a bachelor's degree in computer engineering, electrical engineering, or equivalent, and at least two years of experience related to electronic devices or related fields.
Regarding the term "illumination element," the court found no construction was necessary, noting its ordinary meaning is a bulb, such as an LED or incandescent lamp, that produces light in response to electrical current.
For the term "in communication with said illumination element," the court found no construction was necessary, noting the specification clearly identifies a first switching circuit as being in communication with the element.
The court also found no construction necessary for terms such as "proceed to said special lighting effects" and "interrupt," determining their plain meanings—ranging from transitioning from steady-on to a visual effect, to "on/off" switching—were clear in context.
The court reserved the right to revisit and amend the claim construction as the matter progresses, including during trial.