Free Motion Fitness, Inc. v. Cybex Int'l, Inc.

We vacate the district court’s grant of summary judgment of non-infringement and remand for a determination of literal infringement and infringement under the doctrine of equivalents under the correct claim construction. In this connection, we disapprove the district court’s holding that prosecution history estoppel limits the scope of equivalents. Cybex and Nautilus are free, of course, to reinstate their counterclaims upon remand.

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