INTELLECTUAL PROPERTY CLIENT ALERT: Federal Circuit Vacates Summary Judgment for Non-infringement of Two Toshiba DVD Patents

In Toshiba Corp. v. Imation Corp., No. 11-1204 (Fed. Cir. June 11, 2012), the Federal Circuit vacated a summary judgment for non-infringement of the asserted claims of U.S. Patent Nos. 5,892,751 (“the ‘751 patent”) and 5,831,966 (“the ‘966 Patent”) because the existence of a substantial non-infringing use did not preclude a finding of inducement and limitations from a specification may not be read into the claims.