Justia Patents Opinion Summaries

REAL owns the 989 patent, now expired, directed to methods for locating available real estate properties using a zoom-enabled map on a computer. Move operates and maintains multiple interactive websites that allow users to search for available real estate properties and sought a declaratory judgment that REAL’s patents were invalid and that Move’s websites did not infringe them. REAL counterclaimed, alleging that the “Search by Map” and “Search by Zip Code” functions employed by Move infringed REAL’s claimed search methodologies. In 2009, the parties stipulated to non-infringement based on the district court’s claim construction, and after judgment was entered in favor of Move, REAL appealed regarding only one claim. The Federal Circuit vacated and remanded, holding that “selecting an area” as recited in the claim means that “the user or a computer chooses an area having boundaries, not when the computer updates certain display variables to reflect the selected area.” On remand, the district court entered summary judgment for Move. The Federal Circuit again vacated, holding that while Move cannot be liable for direct infringement, the district court erred by not analyzing inducement under 35 U.S.C. 271(b). View "Move, Inc. v. Real Estate Alliance, Ltd." on Justia Law

FM sued Google for infringing three patents relating to advertising on multiple outlets such as newspapers and websites. The specification characterizes the prior art as inefficient because it requires advertisers to manually ensure that their ads conform to the differing requirements of each advertising venue. The invention is designed to eliminate this inefficiency by automatically formatting the ads to fit each publisher’s requirements and sending them out for publication. In each of the patents, a “central computer” coordinates interactions between sellers (wishing to place ads), media venues, and buyers (targets of the ads). The central computer hosts a number of databases and software processes, including the presentation rules database and the Presentation Generating Program. The district court invalidated of one of FM’s patents as indefinite and a jury found that two others were invalid and not infringed. The Federal Circuit affirmed, rejecting arguments that the court abdicated to the jury its responsibility to construe disputed claim terms; that the court incorrectly denied its motion for a new trial on the grounds that the verdict was against the weight of the evidence; and that the verdicts of infringement and invalidity are irreconcilable. View "Function Media, L.L.C. v. Google, Inc." on Justia Law

The 314 patent, its continuation, the 492 patent, and the 639 patent, relate to electronic commerce; products are offered and purchased through computers interconnected by a network. The patents arise from a software system called “Transact,” developed in 1996 by Open Market. In 2001 Open Market was sold, with the Transact software and patents, to Divine, which was unable to provide support for the complex product and declared bankruptcy. Soverain acquired the Transact software and patents, then sued seven online retailers for patent infringement. The defendants, except Newegg, took paid up licenses to the patents. Newegg declined to pay, stating that its system is materially different and that the patents are invalid if given the scope asserted by Soverain: similar electronic commerce systems were known before the system; the Transact software was generally abandoned; and Newegg’s system, based on the different principle of using “cookies” on the buyer’s computer to collect shopping data, is outside of the claims. The district court awarded Soverain damages and an ongoing royalty and held that the claims were not invalid as obvious. The Federal Circuit reversed in part, holding that claims in the all of the patents are invalid for obviousness. View "Soverain Software, LLC v. Newegg, Inc." on Justia Law

Parallel owns a patent, entitled “Method and Apparatus for Client-Server Communication Using a Limited Capability Client Over a Low-Speed Communications Link.” The application was filed in 1999 and addressed problems in using generic software applications on “handheld and credit-card-sized” computers, often operated over low-speed or wireless networks. Generic applications in that environment occupied considerable storage space on the host computer (they had to include capabilities for adapting to many different settings) and required multiple, data-intensive transfers of information between the server and the computer (they were not designed with the limitations of low-speed networks in mind). The patent’s solution was a “dynamically generated, transient applet,” a small program that typically performs one task. Applets and related technology, “plug-ins,” pre-dated the patent, and could be used to provide “dynamic” capabilities to web pages. The patent claimed a new type of applet, better suited to the needs of “limited capability clients.” Parallel sued 120 defendants with websites that provide applets in response to user requests in a manner that, according to Parallel, infringes the patent. The district court construed terms, including “executable applet,” “data interface capability,” and “dynamically generated” and ruled in favor of most of the defendants. The Federal Circuit affirmed. View "Parallel Networks, LLC v. Abercrombie & Fitch Co." on Justia Law

A jury found that Lawson infringes ePlus’s method and system claims for “electronic sourcing,” which is similar to online shopping. The specification explains that electronic sourcing systems existed in prior art, but those older systems only enabled the user to generate a single purchase order that would be submitted to a single vendor. One important feature of the claimed invention is ability to divide a single requisition (or shopping list) into multiple purchase orders. The patented invention includes a computer that maintains a catalog database of items available from at least two vendors. Vendors may be manufacturers, distributors, or resellers. The user can search vendor catalogs for items that match certain criteria, contact vendors to determine whether a particular product is available, and switch between different catalogs to look at equivalent items. The customer then purchases the desired items. A customer adds the desired item to an “order list;” once the customer is ready to make a purchase, the system uses the order list to build a “requisition,” then determines what inventory will be used to complete the requisition and generates “purchase orders,” which are submitted to vendors. The Federal Circuit reversed in part, finding the system claims indefinite. . View "ePlus, Inc. v. Lawson Software, Inc." on Justia Law

The patent describes a “global paging system utilizing a land-based packet-switched digital data net-work (e.g. the Internet) and a feature for permitting subscribers to remotely designate countries in which they are, or expect to be, located.” The patent asserts that prior art was deficient because it did not fulfill the need for a cheap and efficient global paging system that allows users to “remotely input country designations in which they are to be paged,” noting that other than the roaming feature, the receiving user cannot input designated country locations where he expects to be and that the roam feature is expensive. TPL sued more than 100 defendants for infringement: domestic carriers and handset companies, including AT&T, T-Mobile, Sprint, Motorola, and others; software providers, including Microsoft, Yahoo, and Clickatell; and foreign carriers. The district court dismissed foreign carriers for lack of personal jurisdiction and granted summary judgment of noninfringement in favor of domestic carriers and software providers. The Federal Circuit affirmed the judgment of noninfringement to the domestic carriers, stating that the judgment applies to the foreign carriers, affirmed summary judgment of noninfringement to software providers with respect to certain claims, but vacated judgment of noninfringement with respect to others. View "Tech. Patents LLC v. T-Mobile (UK) Ltd." on Justia Law

Apple alleged that Samsung’s Galaxy Nexus smart-phone infringed patents, including the 604 patent. Asserted claim 6 of the 604 patent is directed to a “unified search” that uses heuristic modules to search multiple data storage locations. Unified search refers to ability to access information on more than one data storage location through a single interface and allows the user to search the device’s local memory and the Internet by entering a single search query. Apple alleged that the Quick Search Box unified search application of Galaxy Nexus infringes claim 6. QSB is a feature of Android, an open-source mobile software platform developed by Google. Any software developer may use Android to create applications and any handset manufacturer can install Android on a device. Galaxy Nexus is one of more than 300 available Android smartphones. The release of the allegedly infringing version of the Android platform predated release of Galaxy Nexus, but Google is not a defendant. The district court enjoined sale of the Galaxy Nexus based on the alleged infringement of the 604 patent. The Federal Circuit reversed. The record did not permit the inference that the allegedly infringing features of the Galaxy Nexus drive consumer demand or the court’s clam construction. View "Apple Inc. v. Samsung Elec. Co., Ltd." on Justia Law

Mirror Worlds sued Apple, alleging direct and induced infringement of three patents directed to searching, displaying, and archiving computer files. The specification discloses a “document streaming” operating system that, unlike traditional operating systems, identifies documents with a time stamp instead of a file name and maintains them in chronologically ordered “streams.” Every document created and every document sent to a person or entity is stored in a main stream. The documents in the stream “can contain any type of data” including “pictures, correspondence, bills, movies, voice-mail and software programs.” By constantly keeping track of all the documents on the computer in these chronologically ordered streams and making the location and nature of file storage transparent to the user, the invention purportedly improves filing operations and enhances the quality of the user’s experience. The district court granted Apple judgment as a matter of law that Apple did not induce infringement. The jury found Apple liable for willfully infringing and awarded $208.5 million in damages. The court granted Apple’s motion for judgment as a matter of law, vacated the verdict, and concluded that Mirror Worlds failed to present substantial evidence of direct infringement and damages. The Federal Circuit affirmed. View "Mirror Worlds, L.L.C. v. Apple, Inc." on Justia Law

WhitServe, owned by Whitmyer, an inventor and a practicing patent attorney holds four patents, namely: “Onsite Backup for Internet-Based Data Processing,” “System Automating Delivery of Professional Services,” “System for Delivering Professional Services Over the Internet,”; and “Web Site Providing Professional Services.” Whitserve sued CPi, which helps other businesses pay their patent maintenance fees on time, alleging infringement by CPi’s system, which are used by a CPi customer, such as a law firm, to generate and send reminders to its clients of upcoming patent or trademark annuity or maintenance fee deadlines. A jury found that CPi failed to prove any claims invalid, that CPi’s systems infringed the patents, that CPi’s infringement was willful, and that WhitServe was entitled to $8,378,145 in damages. The court denied WhitServe’s request for a permanent injunction and did not address a request for a compulsory license. WhitServe’s requests for enhanced damages and attorneys’ fees, prejudgment interest, prejudgment remedy, and disclosure were denied. The Federal Circuit affirmed the finding of infringement, the finding of no anticipation of most, but not all, claims, and denial of fees and sanctions. The case was remanded for a new trial on damages. View "Whitserve, L.L.C. v Computer Packages, Inc." on Justia Law

01 Communique is the owner of the 479 Patent, which relates to technology that enables one computer to access another computer remotely via the Internet. The patent contains five independent claims describing systems, methods, and products for enabling such remote access, as well as numerous claims dependent therefrom. It discloses use of a “locator server computer” as an intermediary between a “remote computer” (the computer seeking access) and a “personal computer” (the computer to be accessed). The locator server computer “includes” software, referred to in the patent as a “location facility,” that locates the personal computer. The district court entered summary judgment of noninfringement, based on construction of a single claim term, “location facility.” The Federal Circuit vacated, finding the claim construction erroneous. View "01 Communique Lab., Inc. v. Logmein, Inc." on Justia Law