Interpretation of Claims When Multiple Invention Objectives Coexist

Judgment Gist

The purpose of the invention plays an important role in the interpretation of claims; when interpreting claims, the relationship between the purpose of the invention and the claims should be taken into account. Where there are multiple invention objectives, it is not the case that every claim must simultaneously achieve all of the invention objectives; where a claim is able to achieve one of the invention objectives and does not expressly define the technical features for achieving the other invention objectives, it is inappropriate, on the ground that the other invention objectives should also be achieved simultaneously, to introduce the technical features in the specification and drawings relating to the achievement of the other invention objectives so as to interpret that claim in a restrictive manner.

Keywords

Civil; infringement of utility model patent right; interpretation of claims; multiple invention objectives

Basic Facts

Ku Company alleged: It is the patentee of the utility model patent numbered 20142040****5 and titled "An electrical connector for a mobile terminal accessory and a mobile terminal accessory having such an electrical connector." Tu Company manufactured, sold, and offered to sell "battery case" products, and Pai Company and Lan Company, as operators of online stores, also sold and offered to sell the "battery case" products at issue. The "battery case" products at issue involve the models S1, S5, S6, S7, S10, S10pro, and S11. Among them, the two models S7 and S11 are the same technical solution; the two models S1 and S6 are the same technical solution; and the three models S5, S10, and S10pro are the same technical solution. Ku Company asserted that the products at issue of all models fall within the scope of protection of claims 1-3, 7, 12, and 13 of the patent at issue. Ku Company held that Tu Company, Pai Company, and Lan Company, without authorization and for profit-making purposes, manufactured, sold, and offered to sell products falling within the scope of protection of the patent right at issue, which constituted joint infringement; they should cease the infringement and jointly compensate for economic losses of RMB 2.6 million and reasonable expenses for enforcing the right of RMB 100,000.

Tu Company argued: (1) The technical solution adopted by the accused infringing products does not fall within the scope of protection of the patent right at issue. (2) The invalidation decision on the patent at issue contains contradictions and unreasonable aspects in its understanding of the claims, and Tu Company has filed a request for invalidation, requesting the court to stay the proceedings. (3) The claims of the patent at issue are unclear, and the context of the specification cannot provide a clear interpretation either, so that the scope of protection of the claims cannot be determined. (4) The products at issue were not manufactured by Tu Company, which is merely the brand owner; Ku Company's accusation that Tu Company manufactured infringing products lacks sufficient evidence and is contrary to the facts. (5) Even if the court finds infringement, the amount of damages claimed by Ku Company is manifestly excessive.

Pai Company argued: It agrees with the defense opinions of Tu Company.

Lan Company argued: It agrees with the defense opinions of Tu Company, and Ku Company has no evidence to prove that Lan Company participated in the acts of selling or offering to sell.

The content of the claims of the patent at issue:

1. An electrical connector for a mobile terminal accessory, characterized by comprising: a plug, the plug having an insertion portion and a first pin portion, the insertion portion having a plurality of electrical contacts, the first pin portion having a plurality of pins, the pins being respectively electrically connected to the electrical contacts, and, after being led out from the end of the insertion portion, extending a first distance in a vertical direction and then extending a second distance in a horizontal direction toward the front end of the insertion portion; and a socket, the socket having an accommodating portion and a second pin portion, the accommodating portion having a plurality of electrical contacts, the second pin portion having a plurality of pins, the pins being respectively electrically connected to the electrical contacts, and being led out from the end of the accommodating portion and extending a third distance in a horizontal direction.

2. The electrical connector according to claim 1, characterized in that the insertion direction of the plug and the accommodating direction of the socket are parallel to each other.

3. The electrical connector according to claim 1, characterized in that the first distance matches the distance from the lower edge of the interface of the mobile terminal corresponding to the plug to the back of the mobile terminal.

7. The electrical connector according to claim 1 or 2, characterized in that the part of the pins of the first pin portion that extends in the vertical direction after being led out from the end of the insertion portion is located in the same plane as the outer side surface of the accommodating portion of the socket.

12. A mobile terminal accessory, characterized by comprising: a housing having a bottom plate and side plates, the side plates being arranged around the periphery of the bottom plate and enclosing, together with the bottom plate, an accommodating groove; an electrical connector arranged on the side plate, comprising: a plug, the plug having an insertion portion and a first pin portion, the insertion portion having a plurality of electrical contacts, the first pin portion having a plurality of pins, the pins being respectively electrically connected to the electrical contacts, and, after being led out from the end of the insertion portion, extending a first distance in a vertical direction and then extending a second distance in a horizontal direction toward the front end of the insertion portion; and a socket, the socket having an accommodating portion and a second pin portion, the accommodating portion having a plurality of electrical contacts, the second pin portion having a plurality of pins, the pins being respectively electrically connected to the electrical contacts, and being led out from the end of the accommodating portion and extending a third distance in a horizontal direction; and a circuit board, arranged in or on the bottom plate of the housing and electrically connected respectively to the pins of the first pin portion and the pins of the second pin portion.

13. The mobile terminal accessory according to claim 12, characterized by further comprising: an expansion device electrically connected to the circuit board.

Paragraph [0006] of the specification of the patent at issue records: In the existing electrical connectors, the plug and the socket are arranged, within the mobile terminal accessory, respectively on opposite sides of the circuit board, so that the plug, the circuit board, and the socket form a sandwich structure within the housing, which makes it impossible to reduce the thickness of the mobile terminal accessory, thereby giving the entire mobile terminal a considerable thickness.

The Guangzhou Intellectual Property Court held that the products of models S1, S5, S6, S7, and S11 belong to the "sandwich" structure expressly pointed out in the specification of the patent at issue; that this technical means is markedly different from claims 1 and 12, does not conform to the purpose of the invention, and should be excluded from the scope of protection of claims 1 and 12. Only in the products of models S10 and S10pro is the circuit board arranged at the end of the socket, and these products possess all the technical features of the claims asserted by Ku Company and fall within the scope of protection of the patent right at issue. Accordingly, on 28 March 2022 the court rendered Civil Judgment (2020) Yue 73 Zhi Min Chu No. 1025: (1) Tu Company shall, from the date this judgment takes legal effect, immediately cease manufacturing and selling products that infringe the patent right at issue; (2) Pai Company and Lan Company shall, from the date this judgment takes legal effect, immediately cease selling and offering to sell products that infringe the patent right at issue; (3) Tu Company shall, within ten days from the date this judgment takes legal effect, compensate Ku Company for economic losses of RMB 300,000 and reasonable enforcement expenses of RMB 40,000; (4) Pai Company shall, within ten days from the date this judgment takes legal effect, compensate Ku Company for economic losses of RMB 50,000 and reasonable enforcement expenses of RMB 10,000; (5) Lan Company shall, within ten days from the date this judgment takes legal effect, compensate Ku Company for economic losses of RMB 50,000 and reasonable enforcement expenses of RMB 10,000; (6) Ku Company's other claims are dismissed. Dissatisfied, Ku Company appealed. On 27 June 2024, the Supreme People's Court rendered Civil Judgment (2022) Zui Gao Fa Zhi Min Zhong No. 1318: (1) items (1) and (2) of the first-instance judgment are upheld; (2) item (6) of the first-instance judgment is set aside; (3) items (3), (4), and (5) of the first-instance judgment are amended to read "Tu Company shall, within ten days from the date this judgment takes effect, compensate Ku Company for economic losses of RMB 2.6 million; Pai Company shall bear joint and several liability for the aforesaid amount of compensation within the limit of RMB 200,000; Lan Company shall bear joint and several liability for the aforesaid amount of compensation within the limit of RMB 400,000"; (4) Tu Company, Pai Company, and Lan Company shall, within ten days from the date this judgment takes effect, jointly compensate Ku Company for reasonable expenses of RMB 100,000; (5) Ku Company's other claims are dismissed; (6) Tu Company's appeal claims are dismissed.

Judgment Opinion

The court's effective judgment held: First, pursuant to Article 59, paragraph 1 of the Patent Law, the claims are the basis for defining the scope of protection of the patent right; the specification and drawings may be used to interpret the relevant content of the claims, and their interpretive function lies in helping a person of ordinary skill in the art to accurately understand the content of the claims, but they cannot replace the status and function of the claims in the process of defining the scope of protection of the patent right. When using the specification and drawings to interpret the claims, since the embodiments are merely illustrations of the invention, in principle the scope of protection of the patent right should not be limited by the illustrative descriptions in the specification and drawings. Second, when the specification and drawings are used to interpret the claims, the purpose of the invention described in the specification plays an important role in the interpretation of the claims, but the relationship between the purpose of the invention and the claims should be taken into account. Where there are multiple invention objectives, it is not the case that every claim must simultaneously achieve all of the invention objectives; where a claim is able to achieve one of the invention objectives and does not expressly define the technical features for achieving the other invention objectives, it is inappropriate, on the ground of achieving the other invention objectives, to introduce the technical features in the specification and drawings relating to the achievement of the other invention objectives so as to interpret the claim in a restrictive manner.

In this case, the content recorded in claims 1 and 12 of the patent at issue is clear and definite in meaning, and does not impose any limitation on the specific arrangement positions of the circuit board and the plug and socket. Upon comparison, the accused infringing products of models S1, S6, S7, and S11 possess all the technical features recorded in claims 1 and 12 of the patent at issue; according to the all-elements rule for determining patent infringement, these four products fall within the scope of protection of claims 1 and 12 of the patent at issue. As for the mounting position of the circuit board, claim 1 of the patent at issue imposes no limitation, and the technical feature of the accused infringing products concerning the mounting position of the circuit board is, relative to the patent at issue, an added technical feature, which does not affect the conclusion of the patent infringement determination. Moreover, even if interpreted in accordance with the principle of conformity to the purpose of the invention, the accused infringing products of the above models also conform to the purpose of the invention of the patent at issue. According to the records of the specification of the patent at issue, the patent at issue aims to solve three technical problems: the problem that the direction of the socket of the electrical connector differs from the direction of the socket of the mobile terminal, affecting usage habits; the problem that the pin portion of the plug extends in the horizontal direction, resulting in an excessively large size of the mobile terminal; and the problem that the plug, the circuit board, and the socket form a sandwich, resulting in a large thickness of the mobile terminal. In response to the above technical problems, claims 1 and 12 of the patent at issue, through the features "after being led out from the end of the insertion portion, extending a first distance in a vertical direction and then extending a second distance in a horizontal direction toward the front end of the insertion portion" and "a socket, the socket having an accommodating portion and a second pin portion, the accommodating portion having a plurality of electrical contacts, the second pin portion having a plurality of pins, the pins being respectively electrically connected to the electrical contacts, and being led out from the end of the accommodating portion and extending a third distance in a horizontal direction," respectively solve the above first and second problems. The electrical connection structure in the accused infringing products of the above models possesses the above technical features, can solve the first two technical problems, and conforms to the above purpose of the invention of the patent at issue. Although a person of ordinary skill in the art may, on the basis of the technical solutions recorded in claims 1 and 12, adopt a manner of connecting the circuit board horizontally with the socket so as to further reduce the thickness of the mobile terminal, this does not mean that only a mobile terminal that must adopt such a connection manner falls within the scope of protection of claims 1 and 12. When designing mobile terminal products, a person of ordinary skill in the art may select the arrangement manner of the circuit board according to specific needs. The first-instance judgment's exclusion of the "sandwich" structure from the scope of protection of claims 1 and 12 constitutes an erroneous interpretation of the content of the claims of the patent at issue and also violates the all-elements rule for determining patent infringement. In summary, the accused infringing products of models S1, S5, S6, S7, S10, S10pro, and S11 all possess all the technical features of the claims asserted by Ku Company, and fall within the scope of protection of claims 1-3, 7, 12, and 13.

Associated Index

Article 2 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Cases of Disputes over Infringement of Patent Rights

Responsible editor: Intellectual Property Court

Source: Intellectual Property Court of the Supreme People's Court, 2026-09-11. Original: https://ipc.court.gov.cn/zh-cn/news/view-6045.html