A geometric orientation should be interpreted relative to an appropriate geometric reference rather than an object as a whole. Here, for example, a “perpendicular” orientation of a substantially planar mounting plate relative to a drive-wheel axis was found to require that the orientation be with respect to the surface of the mounting plate that makes the mounting plate substantially planar, rather than any orientation of the mounting plate assembly as whole. This would be a good case to consult and cite in response to an overly broad interpretation of a geometric relationship that renders a claim limitation essentially meaningless.
Background / Facts: The patents on appeal here from inter partes review proceedings at the PTO are directed to wheelchairs designed to travel stably over obstacles. The claims recite a “mounting plate” for a motor that is “substantially planar” and “oriented perpendicular to the drive wheel axis.”
Issue(s): Whether the claim language, though referring to a substantially planar mounting plate, is broad enough to encompass the orientation of the mounted motor assembly as a whole relative to the drive wheel axis, as in the prior art.
Holding(s): No. “It is unreasonable to read that straightforward language as meaning anything other than that the drive-wheel axis is perpendicular to the surface of the mounting plate that makes the plate substantially planar. In terms of simple geometry, if the plate were translated in space (without rotation) so that it intersected the axis, the axis would intersect the substantially planar surface at a single point (not more) and make a right angle.”