Woodway USA, Inc. v. LifeCore Fitness, LLC

Woodway USA, Inc. v. LifeCore Fitness, LLC The Federal Circuit affirmed the Board’s obviousness determination. The court rejected Woodway’s effort to recast the Board’s prior-art fact findings as an implicit claim construction and found substantial evidence supporting the Board’s motivation-to-combine and nexus determinations. The decision is a useful reminder that the Federal Circuit will not treat every Board application of a claim term to prior art as claim construction, especially where the patentee seeks de novo review of what is really a substantial-evidence dispute. Affirmed. The challenged claims concern a manually powered treadmill with a curved running surface and a safety device coupled to the frame and running belt. Woodway argued that “running surface” should be limited to portions of the belt a runner’s feet would typically contact during normal use, which would exclude the allegedly curved portion of Chickering. The court held the Board did not implicitly construe the term; it made factual findings about Chickering’s disclosure, and in any event Woodway’s narrow reading conflicted with the claim language and specification. Substantial evidence supported the Board’s finding that a skilled artisan would have combined Chickering, Magid, and Sclater to add a one-way safety mechanism, and the Board reasonably rejected Woodway’s teaching-away argument. The court also upheld the Board’s treatment of commercial-success evidence because Woodway failed to establish nexus to the claimed safety features rather than unclaimed product attributes. § 103 claim construction non-precedential § 103 claim construction non-precedential § 103 claim construction non-precedential