Woodway USA, Inc. v. LifeCORE Fitness, Inc. — Ambiguous Prosecution Statements Did Not Narrow Treadmill Claims

Background

Woodway accused LifeCORE’s manual treadmills of infringing claims requiring a safety device that substantially prevents belt rotation in one direction. The district court construed the phrase to require complete prevention based on statements made during prosecution and granted summary judgment of noninfringement.

The Court’s Holding

The Federal Circuit vacated and remanded. Prosecution disclaimer requires a clear and unmistakable surrender. Read in context, Woodway’s statements distinguished prior art that lacked the claimed safety device; they did not unambiguously limit the claims to treadmills permitting no movement at all in the disfavored direction. The term should receive its plain and ordinary meaning.

Key Takeaways

Courts must read prosecution statements in their full context. When multiple reasonable interpretations remain, there is no disclaimer. Summary judgment built on an erroneously narrowed construction cannot stand.

Why It Matters

The decision reinforces the high bar for prosecution disclaimer and preserves infringement questions where real-world mechanisms restrict movement without eliminating it absolutely.