Justia Patents Opinion Summaries

Soverain Software sued Victoria’s Secret and Avon for infringement of its patents relating to virtual shopping carts and to using a hypertext statement so that users can access information about past orders. The district court found that defendants infringed certain claims and that those claims were not invalid. After the district court’s judgment, the Federal Circuit, in 2013, decided Soverain Software LLC v. Newegg Inc., finding certain of the claims invalid as obvious The Federal Circuit then reversed as to Victoria’s Secret and Avon, holding that issue preclusion applies as a result of the Newegg case, and that the asserted claims here are therefore invalid. View "Soverain Software, LLC v. Victoria's Secret Direct Brand Mgmt., LLC" on Justia Law

DDR’s patents are directed to generating a web page that combines visual elements of a “host” website with content of a third-party merchant. Prior art allowed third-party merchants to “lure the [host website’s] visitor traffic away” from the host website; visitors would be taken to the merchant’s website upon clicking the merchant’s advertisement. The patents disclose that, on activation of a third-party hyperlink on a host website, instead of taking visitors to the merchant’s website, the system generates and directs them to a page that displays product information from the merchant, but retains the host website’s “look and feel.” DDR sued NLG, a travel agency that sells cruises online in partnership with travel websites and cruise lines, asserting infringement by providing a system for cruise-oriented (host) websites that allows visitors to book cruises on cruise lines (merchants). In reexamination of the patents based on prior art, the PTO confirmed the patents’ validity. The parties stipulated to construction of terms, including “look and feel” and “visually perceptible elements.” The district court found the patents not invalid and infringed. The Federal Circuit affirmed except with respect to the 572 patent, which it found to be anticipated as a matter of law. View "DDR Holdings, LLC v. Hotels.Com, L.P." on Justia Law

Interoperability, enabling electronic devices to charge and connect to the wireless Internet anywhere, requires compliance with technical standards. The Institute of Electrical and Electronics Engineers (IEEE) publishes the prevailing wireless internet standard. Creating such standards involves collaboration; the chosen standard may include technology developed by different parties, which may be covered by patents. Because the standard requires that devices utilize specific technology, compliant devices necessarily infringe certain claims in “standard essential patents” (SEPs), which can inhibit widespread adoption of a standard. IEEE asks SEP owners to pledge that they will grant licenses to an unrestricted number of applicants on “reasonable and nondiscriminatory” (RAND) terms. Ericsson’s patents are SEPs for IEEE’s standard. Ericsson promised IEEE it would offer licenses at a RAND rate. The accused infringers produce devices incorporating Intel’s wireless chips. Dell claimed that it has a license based on its prior agreement with Ericsson’s subsidiary. In Ericsson’s infringement suit, the court rejected that claim and found that D-Link infringed three Ericsson patents; held that the 625 patent was valid over a prior art; found that Intel violated its obligation to negotiate a royalty rate in good faith; and awarded Ericsson $10 million (15 cents per infringing device). The Federal Circuit affirmed two infringement findings, but reversed as to another; affirmed that the 625 patent was not invalid; and vacated the damages and ongoing royalty awards. View "Ericsson, Inc. v. D-Link Sys., Inc." on Justia Law

Williamson's patent describes methods and systems for “distributed learning” that utilize industry standard computer hardware and software linked by a network to provide a virtual classroom). The system includes a presenter computer that controls information that appears on the audience member’s computer screen, audience member computers that display the presentation and can communicate with the presenter and other audience members, and a distributed learning server that implements a “virtual classroom” over a network, such as the Internet.. Williamson accused defendants of infringement based on their alleged manufacture, sale, use, and importation of systems and methods of online collaboration. The district court construed “graphical display representative of a classroom” and “first graphical display comprising . . . a classroom region” as requiring “a pictorial map illustrating an at least partially virtual space in which participants can interact, and that identifies the presenter(s) and the audience member(s) by their locations on the map.” The court concluded that the limitation, “distributed learning control module,” was a means-plus-function term under 35 U.S.C. 112(6) and that the specification failed to disclose necessary algorithms for performing all claimed functions, so that claims were invalid as indefinite. The Federal Circuit vacated, finding the constructions erroneous. View "Williamson v. Citrix Online, LLC" on Justia Law

The plaintiffs’ patents claim technology for providing security over networks and assert priority to applications filed in the 1990s. They share a specification disclosing a domain name service system that resolves domain names and facilitates establishing “secure communication links.” In one embodiment, an application on the client computer sends a query including the domain name to a “secure domain name service,” which contains a database of secure domain names and corresponding secure network addresses. This allows a user to establish a secure communication link between a client computer and a secure target network address. The accused product, Apple’s FaceTime feature, allows secure video calling between select Apple devices: a caller enters an intended recipient’s e-mail address or telephone number into a device (e.g., iPhone). An invitation is sent to Apple’s server, which forwards the invitation to a network address translator which, in turn, readdresses the invitation and sends it on to the receiving device. The recipient may accept or decline the call. If accepted, servers establish a secure FaceTime call. A jury found infringement and that none of the infringed claims were invalid and awarded damages of $368,160,000. The Federal Circuit affirmed that none of the asserted claims are invalid; that many are infringed by Apple’s product; and the exclusion of evidence relating to the reexamination of the patents-in-suit. The court reversed a finding that the product infringes one claim under the doctrine of equivalents and the court’s construction of the claim term “secure communication link.”View "VirnetX, Inc. v. Cisco Sys., Inc." on Justia Law

Vederi alleged that Google’s “Street View” infringed claims of related patents with a common specification and priority to a common provisional application. The patents relate to methods for creating synthesized images of a geographic area through which a user may visually navigate via a computer. To acquire images, a recording device is mounted on a car that is driven through an area. In one embodiment, one camera points generally horizontally and perpendicularly to the axis of the street to capture front views and some side views of objects lining the streets. The patents disclose that multiple cameras may be used to capture views in different directions. The patents disclose combining images to generate a composite image that provides a field of view wider than that provided by any single image. The district court entered summary judgment of noninfringement. The Federal Circuit vacated, finding that the court erred in its construction of “images depicting views of objects in a geographic area, the views being substantially elevations of the objects in the geographic area” as “vertical flat (as opposed to curved or spherical) depictions of front or side views.” “Views being substantially elevations of the objects” refers to “front and side views of the objects.” Properly construed, the claims do not exclude curved or spherical images depicting views that are substantially front or side views of the objects in the area.View "Vederi, LLC v. Google, Inc." on Justia Law

BuySAFE’s patent claims methods and machine-readable media encoded to perform steps for guaranteeing a party’s performance of its online transaction. In 2011, buySAFE sued Google, alleging that Google infringes claims 1, 14, 39, and 44 of that patent. The district court held the asserted claims invalid because they cover subject matter ineligible for patenting under 35 U.S.C. 101. The Federal Circuit affirmed, citing the approach to section 101 affirmed by the Supreme Court in 2014 in Alice Corp. Pty. Ltd. v. CLS Bank Int’l. View "BUYSAFE, Inc. v. Google, Inc." on Justia Law

MST owns the rights to the 917 patent, which discloses the wireless activation and management of an electronic device without the need to have physical access to the device. The feature is useful because many businesses request that their employees use smartphones to store and transmit sensitive information. Should an employee lose a smartphone, the patent discloses a way to remotely delete sensitive data and methods to remotely deploy software updates and troubleshoot without the need for a constant connection or an initial activation. BlackBerry makes and sells handheld wireless devices and its BES software, which allows its corporate customers to deliver e-mail and other data to their employees’ BlackBerry devices. The BES software allows companies to remotely manage their employees’ devices. It is installed on a company server and communicates with a BlackBerry device by sending data in packets over the cheapest available network. After construing the “establishing a connection between the wireless device and the server” sub-step to mean “initiating wireless communication between a wireless device and the server” the district court held that Blackberry did not infringe the patent. The Federal Circuit affirmed; there was no legally sufficient evidentiary basis on which a reasonable jury could have found that BlackBerry infringes the asserted claims. View "Mformation Techs., Inc. v. Research in Motion Ltd." on Justia Law

Amdocs and Openet compete in the market for “data mediation software,” which helps internet service providers (ISPs), such as Verizon and AT&T, track customer’s network usage and generate bills. When a customer sends an email, surfs the internet, sends a text message, or participates in a video conference, records of the activity are generated at various locations throughout the network. Data mediation software collects, processes, and compiles these records. Openet successfully moved for summary judgment of noninfringement. With regard to three patents, Openet argued that Amdocs was unable to point to actual infringing use and that the accused products did not practice all claim limitations. The district court held that Amdocs did not raise a genuine question of material fact as to whether the accused devices practiced “completing” or “enhance[ing]” “in a distributed fashion,” a requirement which it construed as common to all asserted claims. The Federal Circuit reversed, agreeing with the construction of enhancement and completion, but finding that Amdocs’ documentary evidence describing the structure and operation of the accused product created factual issues regarding whether the product meets these constructions. The district court also granted summary judgment of noninfringement of a fourth patent. The Seventh Circuit vacated, citing erroneous claim construction . View "Amdocs Ltd. v. Openet Telecom, Inc." on Justia Law

ePlus owns patents that relate to methods and systems for electronic sourcing: using electronic databases to search for product information and ordering selected products from third-party vendors. Claim 26 recites a “method comprising the steps of”: “maintaining at least two product catalogs on a database,” “selecting product catalogs to search,” “searching for matching items,” “building a requisition,” “processing the requisition to generate one or more purchase orders,” and “determining whether a selected matching item is available in inventory.” In 2009, ePlus sued Lawson for infringement. The district court found certain claims not invalid, and a jury found that Lawson infringed those claims. The Federal Circuit reversed in part on the ground that the system claims were invalid and that two of the asserted method claims were not infringed, but affirmed the infringement verdict as to claim 26. On remand, the district court modified the injunction in one respect and found Lawson in civil contempt for violating the injunction. During the pendency of Lawson’s appeals, the United States Patent and Trademark Office completed a reexamination of the patent and determined that claim 26 was invalid. The Federal Circuit affirmed and the PTO cancelled claim 26. The Federal Circuit then vacated the injunction and contempt order. View "ePlus, Inc. v. Lawson Software, Inc." on Justia Law