Omnitracs, LLC v. Motive Technologies, Inc.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OMNITRACS, LLC, et al., Case No. 23-cv-05261-RFL

Plaintiffs,

CLAIM CONSTRUCTION ORDER

v. RE: PREAMBLE OF CLAIM 1 OF

THE ’253 PATENT

MOTIVE TECHNOLOGIES, INC.,

Re: Dkt. No. 460 Defendant.

The preamble of Claim 1 of the ’253 Patent states that what is claimed is “[a] vehicle event recorder system configured to be mounted in a vehicle, the vehicle event recorder system comprising” the various claimed elements. ’253 Patent, cl. 1. During argument concerning jury instructions, the parties requested for the first time that the Court determine whether the phrase “configured to be mounted in a vehicle” is itself a claim limitation. For the reasons below, the Court concluded that the phrase does not limit the claims, and issued a corresponding jury instruction. “Generally, . . . the preamble does not limit the claims.” Am. Med. Sys., Inc. v. Biolitec, Inc., 618 F.3d 1354, 1358 (Fed. Cir. 2010). A preamble may be construed as limiting “if it recites essential structure or steps, or if it is ‘necessary to give life, meaning, and vitality’ to the claim.” Catalina Mktg. Int'l,…