PTAB interpretations of "integral" in various mechanical applications

Today's post will take a look at how the Board has interpreted the claim term "integral", and variations thereof, in a few different mechanical applications. In these decisions, the Board has read "integral" to be broader than unitary construction – thus covering parts that are welded together – but not so broad as to cover parts that are held together by friction fitting or that are merely interconnected.



In Ex parte Langan, the Board interpreted "integral extruded exterior metal panel" to cover multiple panels that were welded together.  The Board did not refer to a dictionary, instead citing to Advanced Cardiovascular Sys. and other earlier cases to find that "the term 'integral' covers more than a unitary, or one-piece construction." The Board then applied this construction to the prior art:

While Tsuruda discloses multiple extruded panels, these panels are welded together to completely fuse the panels together, thereby providing an integral structure that is sufficient ton cover either the sidewall or top of a railway passenger vehicle body described in Tsuruda (FF 1-4).

Ex parte Norcom interpreted "integrally attached" to require more than components held together by frictional force. The claim under review recited a container having a structure with sidewall and bottom wall portions, and "an upper portion integrally attached to the structure." The reference disclosed an outer transport container and a removable container within the outer container. The Examiner asserted that the removable container was “integrally attached” to the outer container because “Becker’s components are held integrally together by frictional forces” and “when the flaps on Becker’s container (12) are closed, the components are held integrally together.”

The Board found the Examiner's position to be unreasonable."One of ordinary skill in the art would recognize 'integrally attached' to mean more than simply a smaller container that is removable and separate (does not form a whole) from a larger, outer container." The Examiner "essentially consider[ed] 'integrally attached' to be any two items that are merely in contact, without being organically joined or linked to form a whole." The Board also noted that the Examiner's interpretation of "integral" was inconsistent with the Applicant's Specification and with a dictionary definition.

The Examiner in Ex parte Szweda took a similar position on "integrally formed" and was also reversed. The limitation at issue in was "fastener being integrally formed with a thumb ring formed along a proximal end of the handle". The Examiner cited to a dictionary definition of "integrally" to mean “of, pertaining to, or belonging as a part of the whole; constituent or component. The Examiner then reasoned that since all components were part of the handle, each component was therefore integral with each other. The Board found that this interpretation was unreasonable because it read "integrally formed" out of the claims:  

As noted by Appellants, “by using the open ended terms ‘comprising’ and ‘including’ in the pending claims, it is already understood that both the thumb ring and the fastener form part of the claimed handle” Moreover, Appellants’ interpretation is consistent with how “integrally” is used both in the Specification and by Gingrich.

Reviewing a claim to an extension arm for mounting electronic devices, the Board in Ex parte Oddsen interpreted "integrally formed" and found that the phrase required more than merely interconnected components. Adopting the definition provided by the Examiner (“formed as a unit with another part”), the Board found that " 'integral’ is sufficiently broad to embrace constructions united by such means as fastening and welding.” (Citing Advanced Cardiovascular Sys. v. Scimed Life Sys., 887 F.2d 1070, 1072 (Fed.Cir. 1989.) However, the Examiner had gone too far, interpreting "integrally formed" to cover all interconnected components.

An overly broad interpretation, as the Examiner suggests, would eviscerate the meaning of the phrase integrally formed because it would mean that all components of APA’s channel 14 as modified by the boss of Matsubara or Schwartztrauber are integrally formed merely because they are interconnected to each other in some manner. See Stumbo v. Eastman Outdoors, Inc., 508 F.3d 1358, 1362 (Fed. Cir. 2007) (denouncing claim constructions which render phrases in claims superfluous).