ARCTIC CAT INC., v. GEP POWER PRODUCTS, INC., decided March 26, 2019, Preamble Limitation

U.S. Patent Nos. and 7,420,822 are directed to electrical-connection boxes with an array of openings (page 2).  One preamble recites “a power distribution module for a personal recreational vehicle” (pages 4-5 and 6-7).  Since the body of the claims describe structurally complete inventions (power modules), the vehicle recitation of the preamble is only an intended use and not part of the claim (pages 12-13).   The body of the claims is directed to a housing with a cover and receptacles and a distribution harness without reference to the vehicle (page 14).  Another preamble recites “a personal recreational vehicle,” but the added structure of the preamble does not provide antecedent basis for terms in the body and does not supply structure to make the structure of the body complete (pages 14-16).  The specification summarizes the invention as the module and a vehicle with the module but does not identify a feature of the vehicle that is improved as the vehicle is entirely conventional other than the module (page 16).  A Jepson format was not used (pages 16-17).

Hindsight: Since the application was drafted for a vehicle manufacturer, it may have been beneficial to direct at least one of the independent claims to a vehicle with the vehicle recited in the body of the claim.  A Jepson format may have been used to keep the vehicle in the preamble only.  The specification could have been drafted to indicate a more vehicle-focused benefit, such as resisting separation caused by vehicle movement instead of the benefit of standardization for manufacturing.