Markman Construction of “Controller” in the District of Delaware

The order for the Markman construction in Avid Technology, Inc. v. Harmonic Inc. (DED, Docket 12-627) was issued on May 2, 2017. The case involves U.S. Patent No. 5,495,291 titled “Decompression system for compressed video data for providing uninterrupted decompressed video data output.”

The Court construed the term “controller” to mean “a component or subsystem that causes, directly or indirectly, aspects of operation of a device.” Notably, the detailed description of the ‘291 patent does not include the word “controller,” but does describe a “microcontroller,” and the defendant proposed that the Court limit the claimed “controller” to a “microcontroller.” However, the Court instead held that the patentee used “microcontroller” in the detailed description, which indicated that the patentee understood the meaning of the term and could have claimed it, but instead claimed a “controller.” Accordingly, the Court refused to limit the term “controller” to be a “microcontroller,” and instead, interpreted “controller” to more broadly be “a component or subsystem that causes, directly or indirectly, aspects of operation of a device.”

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