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Chamberlain Group, Inc. v. Lear Corp

The Chamberlain Group, Inc. (Chamberlain) owns U.S. Patent No. 6,154,544 (’544 patent), an invention that improves security in garage door openers. Chamberlain and Johnson Controls Interiors LLC (JCI), Chamberlain’s exclusive licensee with respect to development of radio frequency transmitters for sale to automotive original equipment manufacturers, sued Lear Corp. (Lear), charging Lear’s Car2U transmitter with infringement of claim 4 of the ’544 patent. After a Markman hearing, a claim construction order, Chamberlain Group, Inc. v. Lear Corp., No. 1:05-CV-03449 (N.D. Ill. Sept. 11, 2006) (Initial Markman Order), and a modified claim construction order, Chamberlain Group, Inc. v. Lear Corp., No. 1:05-CV-03449 (N.D. Ill. Feb. 20, 2007) (Modified Markman Order), the United States District Court for the Northern District of Illinois issued a preliminary injunction, Chamberlain Group, Inc. v. Lear Corp., No. 1:05-CV-03449 (N.D. Ill. Mar. 30, 2007) (Preliminary Injunction Order). The trial court, however, stayed that injunction for Lear’s contracts with General Motors Corp. Chamberlain Group, Inc. v. Lear Corp., No. 1:05-CV-03449 (N.D. Ill. Apr. 25, 2007) (Partial Stay Order). Because the district court erred in construing the claim term “binary code,” this court reverses the district court’s claim construction, vacates the preliminary injunction, and remands.

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