Background
Cold Chain LLC owns a patent for an insulated overhead door. Ridge Corporation became the exclusive licensee and sued Kirk NationaLease Co., Truck and Trailer Parts Solutions Inc., and Altum LLC for infringement. The district court granted a preliminary injunction against the defendants. The Federal Circuit previously vacated an earlier injunction because Ridge lacked standing, but after Cold Chain was added as a plaintiff, the district court granted a renewed injunction. The defendants appealed this second order.
The court’s reasoning
The Federal Circuit reviewed the grant of the preliminary injunction de novo for likelihood of success on the merits. The court concluded that the defendants raised substantial questions regarding three claim limitations. First, the claim requires a panel flexible along its entire length, but the accused door uses a rigid sandwich panel modified with compression gaps. Second, the claim requires foam to form the second outermost surface, but the accused door has thermoplastic membranes on both outer surfaces. Third, the term insulated overhead door implies suitability for cold storage, raising questions about the accused door’s properties. Additionally, the court found the plaintiff’s evidence of irreparable harm speculative and insufficient to justify the extraordinary remedy of a preliminary injunction.
What it means going forward
The reversal and remand halt the preliminary injunction, allowing the defendants to continue manufacturing and selling the accused doors pending further district court proceedings. The decision clarifies that claim terms regarding flexibility and surface composition must be strictly construed and that speculative harm is insufficient to support preliminary injunctive relief in patent cases.