Justia Patents Opinion Summaries

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

LAB’s 903 patent claims a method of “arresting or regressing” penile fibrosis, which can result in erectile dysfunction and penile deformation, by the long-term, daily administration of type 5 phosphodiesterase (PDE5) inhibitors. At Eli Lilly’s request, the Patent Trial and Appeal Board conducted inter partes review. The patent claimed priority from a 2002 Provisional Application. The Board first rejected LAB’s argument for the earlier priority date, construed three terms, and concluded that the claim limitation requiring the delivery of a dosage of up to 1.5 mg/kg/day for at least 45 days “would meet the claim requirement of a continuous, long-term regimen,” and that the combination of three prior references rendered the claims unpatentable as obvious. The Federal Circuit vacated, finding two claim constructions erroneous and that the Board did not make factual findings as to whether there was an apparent reason to combine the references to treat penile fibrosis and whether a person of skill in the art would have had a reasonable expectation of success from such a combination. In a separate opinion, the court specifically addressed one prior reference, Whitaker, stating that it may “suggest” long-term daily treatment by noting the beneficial effects of daily treatment (better erectile response and decreased side effects), but that is not enough. Whitaker does not disclose the claimed treatment regimen with sufficient clarity to satisfy the demanding standard for anticipation. View "Eli Lilly & Co, v. Los Angeles Biomedical Research Institute" on Justia Law

LAB’s 903 patent claims a method of “arresting or regressing” penile fibrosis, which can result in erectile dysfunction and penile deformation, by the long-term, daily administration of type 5 phosphodiesterase (PDE5) inhibitors. At Eli Lilly’s request, the Patent Trial and Appeal Board conducted inter partes review. The patent claimed priority from a 2002 Provisional Application. The Board first rejected LAB’s argument for the earlier priority date, finding that the specification of the provisional application did not disclose the dosage limitation, then construed: “an individual with at least one of penile tunical fibrosis and corporal tissue fibrosis”; “arresting or regressing the at least one of the penile tunical fibrosis and corporal tissue fibrosis”; and “continuous long-term regimen.” The Board concluded that the claim limitation requiring the delivery of a dosage of up to 1.5 mg/kg/day for at least 45 days “would meet the claim requirement of a continuous, long-term regimen,” and that the combination of three prior references rendered the claims unpatentable as obvious. The Federal Circuit vacated, finding two claim constructions erroneous and that the Board did not make factual findings as to whether there was an apparent reason to combine the references to treat penile fibrosis and whether a person of skill in the art would have had a reasonable expectation of success from such a combination. View "Los Angeles Biomedical Research Institute v. Eli Lilly & Co." on Justia Law

Strava sought inter partes reexamination of several claims of Icon’s 800 patent, entitled “Methods and Systems for Controlling an Exercise Apparatus Using a USB Compatible Portable Remote Device,” and disclosing “[a] portable system [that] retrieves one or more exercise programs from a remote communication system that provides motivational content for a user exercising upon an exercise mechanism.” During the reexamination, certain claims were cancelled, and others were added. An examiner at the U.S. Patent and Trademark Office found certain claims obvious over various prior art references. The Patent Trial and Appeal Board affirmed the Examiner’s rejection of all the pending claims as obvious, 35 U.S.C. 103(a). The Federal Circuit vacated in part, finding that the Board never made factual findings with a basis in the record or provided the requisite explanation to support its findings with respect to certain claims. View "Icon Health & Fitness, Inc. v. Strava, Inc." 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

Xilinx a Delaware corporation headquartered in California, develops and markets programmable logic devices for electronics systems. Papst, organized and having its principal place of business in Germany, is a nonpracticing entity that does not manufacture or sell products. Papst’s website describes “a global patent licensing and monetization firm specialized in enforcing infringed patents with the goal to conclude a license agreement with the infringer.” Papst has repeatedly filed patent infringement suits in California federal courts. Before acquiring the patents-in-suit, Papst investigated potential infringers and targets for licensing, including 28 companies based, or having significant presence, in California. Papst sent a patent-infringement notice letter and a follow-up letter to Xilinx. Papst’s managing director, its senior counsel, and its Texas-based outside counsel, traveled to California to meet with Xilinx. No agreement was reached. Xilinx sought a declaratory judgment, in the Northern District of California, that Xilinx’s products do not infringe the patents-in-suit and that the patents are invalid. Papst filed an infringement suit against Xilinx in the District of Delaware asserting the same patents. The California court dismissed the declaratory judgment action for lack of personal jurisdiction. The Federal Circuit reversed; the court has specific personal jurisdiction over Papst. Considering the totality of circumstances, the court found “sufficient minimum contacts” and that the exercise of jurisdiction would not be unreasonable. View "Xilinx, Inc. v. Papst Licensing GMBH & Co. KG" 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