On April 4, the U.S. Court of Appeals for the Federal Circuit (CAFC) issued a precedential decision in Littelfuse, Inc. v. Mersen USA EP Corp. clarifying how U.S. district courts handling claim construction are to construe a patent’s independent claims in light of limitations included in dependent claims. While the Federal Circuit found that the District of Massachusetts was correct to give meaning to the term “fastening stem” by looking to uses of “fastening” and “stem” within the patent, the appellate court vacated and remanded a stipulated judgment of non-infringement, as the district court’s construction of certain independent claim terms would render superfluous other claim terms from dependent claims.
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