IP Law Daily, PATENT—Fed. Cir.: Finding of noninfringement affirmed in armor panel patent dispute, (Feb 10, 2026)

By Kevin M. Finson, J.D.

The patent holder failed to show that the district court erred in its interpretation of the limiting factor in the claim construction.

Summary judgment of non-infringement was properly granted with regard to claims for a method for strengthening the edges of armor panels because there was no evidence in the record to show the edge of the accused panels was equivalent in resistance to the central portions of the panels.

A manufacturer of armor panels failed to show any error in the trial court’s finding of noninfringement, the U.S. Court of Appeals for the Federal Circuit has held. The trial court’s underlying claim construction was supported by the specification (Leading Technology Composites, Inc. v. MV2, LLC, No. 24-2056 (Fed. Cir. Feb. 10, 2026)).

Leading Technology Composites, Inc. (LTC) was the owner of U.S. Patent No. 8,551,598 (the ’598 patent), which was entitled “Armoring Panel for Resisting Edge Impact Penetrations by Ballistic Projectiles.” LTC brought suit for infringement of claim 7, which claimed “An armoring panel for resisting edge impact penetrations by ballistic projectiles...” against MV2, LLC (MV2), a competing manufacturer of armor panels. The trial court granted summary judgment of non-infringement. LTC appealed.

Claim construction. LTC argued the trial court erred in construing the entirety of the preamble to claim 7, quoted above, as limiting, instead suggesting that the phrase “for resisting edge impact penetrations” should not be read as a limitation. LTC also argued that, even if the entire preamble was limiting, the trial court had construed the language too narrowly. The appellate court found that the entire preamble was limiting, as the stated purpose of the claimed invention was to solve the problem of delaminations occurring at the edges of armor panels. The trial court had construed this phrase as requiring the edges of the armor panels to resist impact penetration at a similar level to the main body of the armor panels. LTC argued that resistance “at a similar level” was not required by the ordinary meaning of “for resisting,” but the court held that the trial court’s construction was consistent with the specification and that adopting LTC’s broader construction would have essentially written out the “for resisting” language from the claim.

Summary judgment. LTC also argued that two pieces of evidence created a genuine question of material fact on the issue of infringement even under the trial court’s claim construction. These were an email from one of the owners of MV2 which referred to a “fiberglass U-channel” that improved ballistic protection towards the edge of the panel, and the testimony of LTC’s expert on testing performed on the panels in question. The court found that the first item failed to address the relative resistance of the panel’s edge as compared to the main portions of the panel, and the second item was not referred to in LTC’s briefing and therefore forfeited.

The court affirmed the summary judgment of non-infringement.

The Case is No. 24-2056.

Judge: Stark, L.

Attorneys: Jean Lewis (Kramon & Graham, PA) for Leading Technology Composites, Inc. Matthew Sidney Freedus (Powers Pyles Sutter & Verville PC) for MV2, LLC.

Companies: Leading Technology Composites, Inc.; MV2, LLC

Cases: Patent FedCirNews