IP Law Daily, PATENT—Fed. Cir.: ITC’s infringement judgment affirmed in automatic mail sorting machine dispute, (Aug 22, 2025)

By Kevin M. Finson, J.D.

An International Trade Commission opinion finding infringement was affirmed because the challenged claim construction was consistent with the plain and ordinary meaning of the terms and nothing in the claim language, specification, or prosecution history required a different result.

A seller of product sorting robots failed to show any error in an ITC infringement decision, the U.S. Court of Appeals for the Federal Circuit has held. Nothing in the claim language, specification, or prosecution history compelled a different result from the commission’s interpretation of the plain and ordinary meaning of each disputed term (HC Robotics v. ITC, No. 24-1193 (Fed. Cir. Aug. 22, 2025)).

OPEX Corp. (OPEX) was the owner of U.S. Patents Nos. 8,622,194 (the ’194 patent) and 10,576,505 (the ’505 patent), both of which shared a specification and were directed to mail sorting systems using delivery vehicles traveling along tracks to deliver items to a plurality of destination areas. OPEX filed a complaint with the International Trade Commission (ITC) that the Omnisort Gen 2 product produced by HC Robotics and Invata, LLC (collectively, HC) infringed several claims of each patent. The Commission instituted an investigation (No. 337-TA-1293) and eventually determined that the Omnisort Gen 2 product did infringe, after which it issued a limited exclusion order as well as cease and desist orders.

HC appealed, arguing that the Commission erred in its claim construction and that these errors caused an incorrect infringement decision.

“Between.” The Commission had not expressly construed “between” but did address the scope of the term in finding that the ordinary meaning of the term allowed for certain lifts to be “between” the vertical planes established by two arrays of bins even though it extended beyond them, analogous to the way a piece of lettuce may be said to be “between” two slices of bread in a sandwich even if the lettuce is wider than the bread. The Federal Circuit found no error in this construction and no support for HC’s proposed narrower construction which would have required the lifts to not travel past the top or bottom of the arrays of bins.

“Track.” The Commission had construed “track” to mean a system with a defined pathway, course, or route. HC argued that the term ought to have been limited to a fixed structure that guides a moving vehicle, which would exclude the movable lifts of the accused product. The Federal Circuit found that there was nothing in the claim language, specification, or prosecution history that would require excluding moving pieces of track.

“Guide system.” HC argued that the terms “guide system” and the related “drive system” should be limited essentially to the preferred embodiment disclosed in the specification. The court rejected this argument, finding that the claim language required only that the drive system and guide system operate together and that they maintain the orientation of the vehicle as it changes from horizontal to vertical travel.

The Federal Circuit affirmed the commission’s claim construction, and, because HC did not dispute infringement under the Commission’s claim construction, the resulting exclusion and cease and desist orders were also affirmed.

The Case is No. 24-1193.

Judge: Lourie, A.

Attorneys: Edward Naidich (Mei & Mark LLP) for HC Robotics, a/k/a Huicang Information Technology Co., Ltd. and Invata, LLC, d/b/a Invata Intralogistics. Richard P. Hadorn for the ITC. David James Shaw (Desmarais LLP) for Opex Corp.

Companies: HC Robotics, a/k/a Huicang Information Technology Co., Ltd.; Invata, LLC, d/b/a Invata Intralogistics; Opex Corp.

Cases: Patent TechnologyInternet FedCirNews