Justia Intellectual Property Opinion Summaries

Meiresonne is the sole inventor of the 096 patent, titled “Supplier Identification and Locator System and Method,” disclosing a “system whereby a user can identify a supplier of goods or services over the Internet.” It teaches a directory website that contains a plurality of links to supplier websites, “a supplier descriptive portion” located near a corresponding supplier link, “a descriptive title portion” describing the class of goods or services listed on the website, and “a rollover window that displays information” about at least one of the suppliers corresponding to a link. The Federal Circuit affirmed the determination of the U.S. Patent and Trademark Office’s Patent Trial and Appeal Board, on inter partes review, that four claims are unpatentable under 35 U.S.C. 103. The Board’s fact finding that prior art references do not teach away from combining text descriptions with additional information in a rollover viewing area is supported by substantial evidence. View "Meiresonne v. Google, Inc." on Justia Law

IV sued Capital One, alleging infringement of three patents. Capital One asserted antitrust counterclaims against IV under the Sherman Act and moved for summary judgment on IV’s infringement claims, arguing that the 081 and 002 patents were invalid under 35 U.S.C. 101. In a related proceeding, the district court entered a partial summary judgment order of ineligibility under section 101 for the 084 patent. The district court invalidated the 081 and 002 patents under section 101 and barred IV from proceeding on its infringement claims as to the 084 patent under a collateral estoppel theory. The Federal Circuit, having affirmed in the related proceeding, also affirmed in favor of Capital One. The partial summary judgment order with respect to the 084 patent met the finality prong for the purposes of collateral estoppel. The claims of the 081 patent are, at their core, directed to the abstract idea of collecting, displaying, and manipulating data, and are patent-ineligible; taken individually or in combination, the recited limitations neither improve the functions of the computer itself, nor provide specific programming, tailored software, or meaningful guidance for implementing the abstract concept. The court noted that the 002 patent had been found ineligible in a related proceeding. View "Intellectual Ventures I LLC v. Capital One Financial Corp." on Justia Law

IV sued insurance companies, alleging infringement of three patents. The insurers moved to dismiss IV’s 581 patent infringement claims for lack of standing and argued that all three patents were directed to ineligible subject matter under 35 U.S.C 101. After concluding that IV did not own the rights to the 581 patent, the district court dismissed those claims for lack of standing, finding that a particular assignor did not assign any rights in or to the then-pending application to the 581 patent, thus breaking a chain in ownership of the patent. The court also found the three patents ineligible under section 101. The Federal Circuit agreed that IV had not been assigned any rights in the 581 patent and lacked standing. The court also agreed that the 434 patent, reciting “no more than routine steps involving generic computer components and conventional computer data processing activities to accomplish the well-known concept of creating an index and using that index to search for and retrieve data” was patent-ineligible. The 002 patent, reciting the abstract idea of remotely accessing user-specific information, identifies a need, but the claims fail to provide a concrete solution to address that need. View "Intellectual Ventures I LLC v. Erie Indemnity Co." on Justia Law

Prism’s patents describe methods and systems for managing access to protected information provided over certain “untrusted” networks. The technology involves an access server, an authentication server, and a client. The access server forwards client requests for protected information to the authentication server. If the authentication server, using stored identity data, successfully authenticates the client, the client receives authorization to access the information. After the court construed “Internet Protocol network” and similar limitations as “an untrusted network using any protocol of the Internet Protocol Suite including at least one of IP, TCP/IP UDP/IP, HTTP, and HTTP/IP.” and defined an “untrusted” network as “a public network with no controlling organization, with the path to access the network being undefined and the user being anonymous,” a jury found Sprint liable for infringement and awarded Prism $30 million in reasonable-royalty damages under 35 U.S.C. 284. The district court denied Prism’s motion for additional monetary relief for times after the period Prism said was covered by the jury verdict. The Federal Circuit affirmed, upholding the court’s admission of evidence of a settlement between Prism and AT&T in a suit involving similar allegations and other evidentiary rulings. View "Prism Technologies LLC v. Sprint Spectrum L.P." on Justia Law

The 336 patent discloses a microprocessor with two independent clocks—a variable frequency system clock connected to the central processing unit (CPU) and a fixed-frequency clock connected to the input/output (I/O) interface. The patent teaches improving microprocessor performance by decoupling the CPU and I/O clocks, so that “optimum performance can be achieved by each.” In five separate litigations, the parties stipulated to non-infringement based on the district court’s construction of “an entire oscillator disposed upon said integrated circuit substrate.” The Federal Circuit consolidated the appeals and vacated, holding that the district court erred in a portion of its construction of “entire oscillator.” An ”entire oscillator disposed upon said integrated circuit substrate” is “an oscillator located entirely on the same semiconductor substrate as the central processing unit that does not require a command input to change the clock frequency and whose frequency is not fixed by any external crystal.” View "Technology Properties Ltd. v. Huawei Technologies Co., Ltd." on Justia Law

The Axcess patent, entitled “System and Method for Authenticating a Web Page,” relates to "systems and methods for authenticating a web page.” The Patent Trial and Appeal Board determined that it was a covered business method (CBM) patent under the America Invents Act (AIA), 125 Stat. 284, and that certain claims were unpatentable as obvious under prior art. The Board rejected a claim by Axcess that the patent was ineligible for CBM review because it was not directed to a financial product or service and can be used by institutions other than financial institutions. The Federal Circuit reversed, finding that the Board’s characterization of a CBM was inconsistent with the statutory definition: a patent that claims a method or corresponding apparatus for performing data processing or other operations used in the practice, administration, or management of a financial product or service. If a CBM patent is to be usefully distinguished from all other patents, the distinction will not lie based on non-statutory phrases like “incidental to” or “complementary to” financial activity. Necessarily, the statutory definition of a CBM patent requires that the patent have a claim that contains, however phrased, a financial activity element. View "Secure Axcess, LLC v. PNC Bank National Association" on Justia Law

Scag, which manufactures commercial riding lawnmowers, developed a suspended operator platform for a ride-on lawnmower or other riding light utility vehicle connected to a rigid chassis by a suspension system. The operator platform supports the entire body of the operator. The suspension system suspends the operator platform from the chassis in a manner that isolates an operator from vibrations, or shock loads, generated by the mower during use or when driven over uneven terrain. The operator platform can suspend or isolate some controls from the rigid chassis. Scag commercialized the system, which is disclosed in the 475 patent, in its Cheetah line of lawnmowers. In 2015, Toro introduced riding lawnmowers with suspended operator platforms to compete with Scag’s Cheetah line. The steering controls in Toro’s riding lawnmowers are connected to the chassis, not the operator platform. Scag filed an infringement action and obtained a preliminary injunction. The Federal Circuit affirmed, finding that Scag established a likelihood of success that the accused products infringe claim 21 of the 475 patent and that there is not a substantial question of validity as to claim 21. View "Metalcraft of Mayville, Inc. v. Toro Co." on Justia Law

Organik and Dow both manufacture opaque polymers, hollow spheres used as additives to increase paint’s opacity. Dow has maintained its worldwide market-leader position through a combination of patent and trade-secret protections. Dow filed a complaint with the International Trade Commission requesting an investigation into whether Organik’s opaque polymer products infringed four Dow patents. The Commission granted Dow’s request, and the parties began discovery. During the proceedings, Dow amended its complaint to add allegations of trade secret misappropriation when it discovered that Organik may have coordinated the production of its opaque polymers with the assistance of former Dow employees. As Dow attempted to obtain discovery relating to the activities of those employees, Dow discovered spoliation of evidence “on a staggering scale.” The Federal Circuit affirmed the Commission’s imposition of default judgment and entry of a limited exclusion order against Organik as sanctions for the spoliation of evidence. Organik’s “willful, bad faith misconduct” deprived Dow of its ability to pursue its trade secret misappropriation claim effectively. The record supports the limited exclusion order of 25 years with the opportunity for Organik to bypass that order at any time if it can show that it has developed its opaque polymers without using Dow’s misappropriated trade secrets. View "Organik Kimya v. International Trade Commission" on Justia Law

Personal Web’s patent describes and claims methods (or devices for carrying out methods) of locating data and controlling access by giving a data file a substantially unique “True Name” that depends on its content. The patent describes generating a True Name using mathematical algorithms (hash functions) that use a file’s contents to generate a small-size identifier. It calls for comparing that name with values in a network, determining whether a user is authorized to access the data, and providing or denying access based on that determination. Apple petitioned for inter partes review, arguing unpatentability under 35 U.S.C. 103, for obviousness based on a combination of one reference that focuses on a system for backing up or restoring data and one that focuses on a system for managing rights to access data. The Patent Trial and Appeal Board agreed with Apple. The Federal Circuit affirmed the Board’s claim construction of “content-dependent name,” “content-based identifier,” and “digital identifier,” but vacated the obviousness determination because the Board did not adequately support its findings that the prior art disclosed all elements of the challenged claims and that a relevant skilled artisan would have had a motivation to combine the references to produce the claimed inventions with a reasonable expectation of success. View "Personal Web Technologies, LLC v. Apple, Inc." on Justia Law

MPHJ’s 173 Patent, entitled “Distributed Computer Architecture and Process for Document Management,” describes a system and method that “extends the notion of copying from a process that involves paper going through a conventional copier device, to a process that involves paper being scanned from a device at one location and copied to a device at another location.” The patent calls its invention a “Virtual Copier” whose purpose is “to enable a typical PC user to add electronic paper processing to their existing business process,” and states that it replicates an image “using a single GO or START button, to do a similar operation in software so that the image gets seamlessly replicated into other devices or applications or the Internet.” The Patent Trial and Appeals Board, on inter partes review, found certain claims invalid for anticipation of obviousness. The Federal Circuit affirmed, citing Supreme Court precedent that “when unexpired patents are reviewed by the Board, the claims are given their broadest reasonable interpretation consistent with the specification and the prosecution history, from the viewpoint of persons skilled in the field of the invention,” and upholding the Board’s constructions of the claim terms “application” and “rendering.” View "MPHJ Technology Investments, LLC v. Ricoh Americas Corp." on Justia Law