Federal Circuit Gives "Joined" Its Ordinary, Broad Meaning in a Lighted Cover Plate Appeal

On October 5, 2026, the Federal Circuit decided O'Reilly Winship LLC v. SnapRays LLC, No. 2025-1422, a nonprecedential appeal from the Northern District of Texas. The opinion describes O'Reilly Winship (OWL) and SnapRays (SnapPower) as competitors in the lighted cover plate industry. OWL sued for a declaration of non-infringement of U.S. Patent Nos. 9,871,324 and 9,035,180, and SnapPower counterclaimed for infringement by OWL's BriteOWL cover plates. The district court granted OWL summary judgment of non-infringement and denied SnapPower's motion for partial summary judgment of infringement (slip op. 2-3).

The word "joined"

Claim 1 of the '324 patent recites an active cover plate with at least one clip extending rearward from the faceplate, the clip comprising a contact, a resilient strip supporting a front side of the contact, "wherein the contact is joined to the resilient strip and extends through an aperture in the resilient strip," and a rear insulator covering a rear side of the contact. The district court found that the BriteOWL contact, which rests inside a hole in the spring clip and is held in place by a separate rear cover, was not "joined to" the strip. The Federal Circuit disagreed. It noted that the claim does not specify how the contact is joined, that the specification lists many joining techniques, including adhesive, heat welding, press fit, and snap fit, and that dictionary definitions did not justify a narrower reading. Under the plain and ordinary meaning, the court held, the only disputed limitation is met (slip op. 4-8).

The court reversed summary judgment of non-infringement on claims 1, 2, 4, 8, 9, and 10 of the '324 patent, remanded with instructions to grant partial summary judgment of infringement on claims 1, 2, and 8, and remanded claims 4, 9, and 10 for further proceedings because they were not part of SnapPower's motion (slip op. 8).

What the court affirmed

SnapPower's other arguments failed. Applying the parties' agreed reading of "configured to" as "designed to," the court affirmed non-infringement of claims 11, 12, 13, and 15 of the '180 patent (slip op. 8-10). It also affirmed non-infringement of claims 13, 14, 15, 17, 19, 20, 23, and 25 of the '324 patent and claims 1, 2, 3, 5, and 6 of the '180 patent, upholding the district court's readings of "sandwiched between" and "aperture" and its analysis of claim 1 of the '180 patent, which followed SnapPower's own claim mapping (slip op. 10-14).

The disposition reads reversed-in-part, affirmed-in-part, vacated-in-part, and remanded, with no costs. The opinion does not separately identify which ruling it vacated, and it does not address validity or damages. The case returns to the Northern District of Texas for further proceedings (slip op. 14-15).