SeaChange: Over dissent, Court allows broad claim interpretation

NCube v. SeaChange (Fed. Cir. 2006).

In yet another challenge to claim scope, nCube argued that SeaChange’s patent improperly expanded the scope of the network architecture patent. Here, the claimed “upstream manager” was not expressly limited to working with either physical or logical memory.  However, the specification, in describing the “present invention” only spoke of logical memory. 

Here, the majority (Rader, J.) allowed a broad claim interpretation of upstream manager (including operations with physical memory) that was required to find infringement. 

In dissent (Dyk, J.) would have held that the limited language of the specification limited the scope of protection — especially because the logical memory addressing was seen as a critical aspect of the invention.