Recent Markman-speak.

In a patent for a “combination money clip and [credit] card holder” for “removably retaining paper currency [folding money] and cards therein,” the District Court ruled that:  “One-piece holder’ is construed as ‘a holder having no parts that separate from the unit during normal operation and containing no parts that are not integrally formed.'”  Storus Corp. v. Restoration Hdwre., (N.S. Calif. 3/22/2007). ISINIP note: “holder” means “holder” but “one-piece” means much more.

Patent “claim construction is an analysis wholly independent from plaintiff’s theory of infringement and is not influenced by such.”  Baldwin Graphic Systems v. Siebert, Inc., (N.D. Ill. 3/21/2007).   ISINIP note: does that suggest an essential defect in the precedential approach. 
“Hence, our construction of the claim term is not importing a limitation from the specification, but construing the claim in the context of the necessary limitations in the patent itself.” Id.  ISINIP note:  No confusion is reasonably foreseeable from this distinction drawn by the CAFC.