Justia Patents Opinion Summaries

Antor owns the 961 patent relating “to a method and apparatus for transmitting information recorded on digital disks from a central server to subscribers via a high data rate telecommunications network.” The goal of the ’961 patent is to allow subscribers to access and to receive information (digital media such as music, images, documents, video, and software) stored on information systems over a telecommunications network. On reexamination the Patent and Trademark Office rejected the patent as anticipated and obvious over four references. The Federal Circuit affirmed. The Board correctly held that the existence of licenses under the patent is, alone, insufficient to overcome the prima facie case of obviousness View "In re: Antor Media Corp." on Justia Law

Apple claimed that Samsung smartphones, the Galaxy S and the Infuse, and its Galaxy Tab 10.1 tablet infringed four Apple patents. Apple sought a preliminary injunction to block importation and U.S. sales. The district court denied the motion with respect to each device and all asserted patents. As to one patent, the court found that Apple failed to show likelihood of success on the merits because the patented design did not cover functional features and the design aspect was likely anticipated. As to others, the court held that Apple failed to show that it would likely suffer irreparable harm from continuing infringement while the case was pending, rejecting a claim of erosion of design distinctiveness. The court concluded that the absence of a nexus between the claimed design and the loss of market share, coupled with delay in seeking an injunction, undercut a claim of irreparable harm. With respect to a patent for the tablet computer, the court found that the design was not dictated by functionality and may have been obvious. The Federal Circuit affirmed with respect to three patents. With respect to the fourth, the court vacated, holding that the district court erred in its validity analysis. View "Apple, Inc. v. Samsung Elec. Co., Ltd." on Justia Law

Leader, a software company, owns the 761 patent, which discloses a system that manages data that may be accessed and created by multiple users over a network. The patent improves upon conventional systems by associating data "with an individual, group of individuals, and topical content, and not simply with a folder, as in traditional systems." The system achieves this improvement by having users collaborate and communicate through boards that are accessible through an Internet browser and appear as a webpage. To facilitate those user-facing functions, the data management system employs metadata, tagged to data being created, to capture the association between the data and its context. As users create and change their contexts, the data (files) and applications automatically follow. Prior to filing the 761 application in 2003, Leader developed Leader2Leader.® Facebook claimed that the earlier product, publicly used and on sale prior to December 10, 2002 fell within the scope of the asserted claims of the 761 patent, rendering them invalid under 35 U.S.C. 102(b). The district court ruled in favor of Facebook. The Federal Circuit affirmed, finding the verdict supported by substantial evidence. View "Leader Tech., Inc. v. Facebook, Inc." on Justia Law

The 435 patent relates to an automated financial accounting system that allows a user to connect to the computers of companies with which the user conducts business for transmission of financial information . Plaintiff asserted that Quicken and QuickBooks products infringed claims that contain an "access means" limitation. The parties agree that this is a means-plus-function limitation performed by a processor. As such, the specification of the 435 patent must contain an algorithm to perform the function associated with the "access mean"” limitation, or the limitation is indefinite. The district court entered summary judgment of invalidity. The Federal Circuit affirmed, holding that the "access means" limitation is indefinite. View "Noah Systems, Inc. v. Intuit, Inc." on Justia Law

The patents are directed to regulating access to content that is delivered through a computer network. Digital-Vending sued three businesses involved in online education, alleging infringement. The district court issued a claim construction order. Two defendants entered into settlements. The third, University of Phoenix, sought summary judgment of non-infringement. Digital-Vending filed a motion for reconsideration of construction of the term "registered user." The district court granted for summary judgment of non-infringement and entered judgment in favor of Phoenix. The Federal Circuit vacated in part, finding that the determination was based on erroneous construction, and affirmed in part. View "Digital-Vending Servs. Int'l, LLC v. Univ. of Phoenix, Inc." on Justia Law

MySpace, FOX, and Craigslist sought declaratory judgment that certain patents owned by GraphOn were invalid and not infringed by plaintiffs. The patents related to the ability to create, modify, and store database records over a computer network. The District Court granted plaintiffs summary judgment. The Federal Circuit affirmed. The district court's claim construction of "database" was reasonable and supported by the context; its overall conclusion that the claims were anticipated or obvious was appropriate. The case was properly decided under sections 102 and 103 of the Patent Act and not under section 101. View "MySpace, Inc. v. Graphon Corp." on Justia Law

Plaintiff owns patents, directed to a computer-aided method and system for processing credit applications from car dealers over electronic networks. The patents claim priority to and incorporate the 403 patent, filed in 1995. The district court entered judgment of noninfringement on certain claims; of invalidity for failure to claim patentable subject matter under 35 U.S.C. 101 with respect to other claims; and of invalidity for indefiniteness on others. The Federal Circuit affirmed in part and reversed in part. With respect to infringement, the district court improperly carved-out the Internet from its construction of "communications medium" and improperly construed "central processing means." Finding "central processing means" indefinite, the court invalidated three claims for failure to recite sufficient structure to perform claimed functions. Certain claims were invalid as being directed to an abstract idea preemptive of a fundamental concept or idea that would foreclose innovation in the area. View "Dealertrack, Inc. v. Huber" on Justia Law

The jury found that Amazon's 1-click purchasing system infringes plaintiff's 710 patent, entitled "Object-Based On-Line Transaction Infrastructure," which covers an online purchasing system, but that all of the claims of the patent were invalid, and that Amazon did not infringe any of the other patents at issue. The judge granted a plaintiff's post-verdict motion and ruled that the 710 patent claims were not invalid. The Federal Circuit reversed the post-verdict ruling and held that each asserted claim of the 710 Patent is invalid as anticipated and the asserted claims of the other patents remain valid and not infringed.View "Cordance Corp. v. Amazon.com" on Justia Law

The 545 patent claims a method for distributing copyrighted products (songs, movies, books) over the Internet where the consumer receives a copyrighted product for free in exchange for viewing an advertisement, and the advertiser pays for the copyrighted content. The district court dismissed an infringement claim. The Federal Circuit reversed and remanded. The patent claims a "process" within the meaning of 35 U.S.C. 101. View "Ultramercial, LLC . Hulu, LLC" on Justia Law

The rejected patent claim is one of several that describe a system for sending information (electronic mail) from an originating processor (personal computer) to a destination processor (mobile computer) using an intermediary (radio frequency receiver). Prior art systems required connection to a public switched phone line and were limited by difficulty in locating a phone jack. The Board of Patent Appeals affirmed the rejection, construing the term "destination processor," to mean the "particular end node device to which the intended user recipient of electronic mail has immediate and direct physical access when accessing and viewing electronic mail;" determining that the applicant was not entitled to claim priority; and finding that the claim was anticipated by prior art. The Federal Circuit affirmed. The Board properly relied on the written description in construing "destination processor." Nothing in 35 U.S.C. 301 prohibits an examiner from determining, on re-examination, whether a priority date was properly claimed during the original examination; such a determination was proper in this case because the examiner did not consider priority during the original prosecution. View "In re NTP, Inc." on Justia Law