Justia Patents Opinion Summaries

Synopsys’s “Gregory Patents” relate to the logic circuit design process. In the early days, a designer was required to prepare a detailed schematic diagram that identified individual hardware components and the interconnections between them or a set of Boolean logic equations that specified the precise functionality of the design. A fabrication facility would then build the corresponding physical circuit. Over time, logic circuits became more complex; designers began to focus on the higher-level functionality of their designs and became less concerned with the detailed schematics or Boolean logic equations necessary to implement that functionality. The Gregory Patents describe “control flow graphs,” and “assignment conditions,” that provide a scheme to translate functional descriptions of logic circuits into hardware component descriptions of those circuits without requiring the designer to instantiate individual hardware components. In an infringement suit, the court invalidated certain claims under 35 U.S.C. 101, as directed to ineligible subject matter. The Federal Circuit affirmed. The claims are directed to the abstract idea of translating a functional description of a logic circuit into a hardware component description. This idea can be, and was, performed mentally or on paper by one of ordinary skill in the art. The claims do not require the involvement of a computer and cannot be characterized as an improvement in a computer as a tool. View "Synopsys, Inc. v. Mentor Graphics Corp." on Justia Law

The specification and prosecution history of Poly-America’s patent contain clear and unequivocal statements that the inventor intended to limit the claimed invention to a trash bag with “short seals” at its upper corners that extend inwardly to narrow the bag’s upper opening. Poly-America sued API for infringement. Poly-America proposed that “short seal” be construed as “a seal that inseparably welds or joins the first and second elastic drawstrings and the first and second panels of the bag.” The district court instead adopted API’s proposed construction: “A seal for securing the elastic drawstring, which seal is located adjacent to a side seal, and that is not substantially aligned with the side seal, but extends inwardly from the interior edge of the side seal,” as consistent with the specification and the prosecution history. Under that construction of short seal, the accused device would not infringe because API’s accused bags are conventional drawstring trash bags with short seals that are substantially aligned with the side seal—i.e., the short seals do not extend inwardly, so the width of the relaxed upper opening is equal to the bag proper width. The Federal Circuit affirmed. Given the inventor’s disavowal, the district court correctly construed the term “short seal” to require that such seals extend inwardly. View "Poly-America, L.P. v. API Indus., Inc." on Justia Law

Massachusetts Institute of Technology sued Shire Pharmaceuticals, for infringement of patents that are directed to three-dimensional scaffolding for growing cells in vitro to produce organ tissue in vivo. Following the district court’s construction of the terms “vascularized organ tissue” and “cells derived from a vascularized tissue” and its determination that the term “three-dimensional scaffold” was not indefinite, the parties stipulated to a final judgment of validity and infringement. The Federal Circuit affirmed, finding no error in the district court’s claim construction. View "Mass. Inst. of Tech. v. Shire Pharma., Inc." on Justia Law

FairWarning sued Iatric Systems for infringing claims of the 500 patent, which is titled “System and Method of Fraud and Misuse Detection” and discloses ways to detect fraud and misuse by identifying unusual patterns in users’ access of sensitive data. The specification describes systems and methods to detect fraud by an otherwise-authorized user of a patient’s protected health information (PHI). According to the specification, pre-existing systems were able to record audit log data concerning user access of digitally stored PHI. The claimed systems and methods record this data, analyze it against a rule, and provide a notification if the analysis detects misuse. The Federal Circuit affirmed dismissal of the suit. The patent claims patent-ineligible subject matter under 35 U.S.C. 101. The claims were directed to a “basic and well-established” abstract idea: analyzing records of human activity to detect suspicious behavior. They contained nothing to transform the abstract idea into a patentable concept, but only contain an instruction to apply the abstract idea “using some unspecified, generic computer.” View "Fairwarning IP, LLC v. Iatric Sys, Inc." on Justia Law

Apple alleged infringement of five patents that cover various aspects of the operation of smartphones. The district court granted summary judgment that Samsung’s accused devices infringed the 172 patent; a jury found the 647 and 721 patents infringed, infringed and not invalid. The court awarded Apple $119,625,000 in damages and ongoing royalties. The jury found that Samsung had not infringed two other patents. Samsung’s countersuit alleged infringement of its patents. The jury found Apple had infringed one patent and awarded $158,400 in damages but found that Apple had not infringed the other. A Federal Circuit panel reversed in part, finding that Apple failed to prove that the accused Samsung products use an “analyzer server” as the Federal Circuit has previously construed that term with respect to one Apple patent and that the asserted claims of two Apple patents would have been obvious based on the prior art. The court affirmed the judgment of non-infringement of two Apple patents, affirmed the judgment of infringement of Samsung’s patent, and affirmed the judgment of noninfringement of Samsung’s other patent. On rehearing, en banc, the court vacated its panel decision and reinstated the district court’s judgment as to the 647, 721, and 172 patents as supported by substantial evidence. View "Apple, Inc. v. Samsung Elec. Co., Ltd." on Justia Law

IV owns the 050 patent entitled, “Distributed Content Identification System,” directed to methods of screening emails and other data files for unwanted content; the 142 patent, entitled, “Automated Post Office Based Rule Analysis of E-Mail Messages and Other Data Objects for Controlled Distribution in Network Environments;” and the 610 patent, entitled, “Computer Virus Screening Methods and Systems.” IV sued two developers of anti-malware and anti-spam software for infringement. A jury found that the asserted claims were not invalid under 35 U.S.C. 102 and 103 and that certain claims were infringed. After trial, the court held that the asserted claims of the 050 and 142 patents were patent-ineligible under 35 U.S.C. 101, but that the asserted claim of the 610 patent was eligible. The Federal Circuit affirmed as to the 050 and 142 patents, stating that “each step does no more than require a generic computer to perform generic computer functions.” The court reversed as to the 610 patent, which is “not directed to a specific improvement to computer functionality,” but to the use of conventional or generic technology in a nascent but well-known environment. View "Intellectual Ventures I LLC v. Symantec Corp." on Justia Law

Lyda’s patents describe “obtaining real time responses to remote programming” by “allow[ing] persons viewing or listening to a broadcast to respond to the broadcast in real time without requiring a personal computer.” Lyda sued CBS for infringement in connection with the television show “Big Brother.” Lyda alleged that audience members could influence the show by voting using cell phone text messages. The complaint alleged that CBS engaged an independent contractor to test the system and that the independent contractor used unnamed third parties to perform the voting. The district court dismissed, finding that the allegations implicated a theory of joint infringement and that Form 18, the Federal Rules’ standard for specificity in pleading direct infringement, does not apply to joint infringement claims. The court stated that “Plaintiff’s allegations are simply too vague, even under the Form 18 standard, to articulate a claim for relief.” The Federal Circuit affirmed, applying the “Twombly/Iqbal” standard, which requires pleading facts sufficient to allow a reasonable inference that all steps of the claimed method are performed and either one party exercises the requisite “direction or control” over the others’ performance or the actors form a joint enterprise such that performance of every step is attributable to the controlling party. View "Lyda v. CBS Corp." on Justia Law

Drone’s patents are directed to systems for remotely controlled machines. Before the invention, conventional remote-control systems included a remote-controlled device (e.g., a model airplane) and a handheld device with a stick that controlled movement in two directions. Controlling three directions required simultaneous use of both hands. Drone’s patents purport to enable a user to synchronize the movement of a remote-controlled device with the movement of a controller: moving the handheld control itself causes a synchronous movement of the airplane. After entering default judgment as a sanction for Parrot’s failure to comply with discovery orders, the district court awarded Drone damages for Parrot’s infringement of the patents and awarded Drone attorney fees. The Federal Circuit vacated. The district court abused its discretion in issuing discovery orders requiring Parrot to turn over its on-board source code and in entering a default judgment for failure to comply. The court upheld denial of a motion to dismiss Drone’s complaint for lack of standing; Parrot had argued that the assignments to Drone were invalid because the person named on the patents and who assigned the patents to Drone was not the true inventor. On remand, Parrot may raise the affirmative defense of improper inventorship under 35 U.S.C. 102(f). View "Drone Techs., Inc. v. Parrot S.A." on Justia Law

Husky’s 536 patent discloses a molding machine having a clamp assembly comprising a stationary platen, a movable platen, tie bars, tie bar locks that couple the tie bars to the movable platen, and clamp actuators that supply a clamping force to the tie bars. On inter partes review, the Patent Trial and Appeal Board found several claims invalid as anticipated. The Federal Circuit dismissed, for lack of jurisdiction, Husky’s argument that the Board’s determination during the institution phase that assignor estoppel cannot bar an assignor or his privies from petitioning for inter partes review. Any question concerning assignor estoppel necessarily implicates who may petition for review; such a question falls outside of the narrow exceptions to the otherwise broad ban on judicial review of the decision whether to institute inter partes review. The court vacated with respect to four claims that were upheld by the Board. The Board erred in determining that one prior reference did not incorporate another for purposes of anticipation and provided no further reasoning why claims the were not anticipated. View "Husky Injections Molding Sys., Ltd. v. Athena Automation Ltd." on Justia Law

Sprint's patents concern voiceover-IP technology for transmitting calls over the internet, instead of through traditional telephone lines. The patents discuss the hand-off between traditional telephone lines (a “narrow-band network” or “circuit-switched network”) and a data network (a “broadband network” or “packet-switched network”), such as the internet. Both the “control patents” and the “ATM interworking patents” describe the use of a “processing system,” which receives a signal from a traditional telephone network and processes information related to the call to select the path that the call should take through the data network. In the control patents, a “communications control processor” selects the network elements and the connections for the path. In the ATM interworking patents, a “signaling processor” or a “call/connection manager” selects the virtual connections by which the call will pass through the ATM network and performs other functions, including validation, echo control, and billing. Both specifications disclose that logic for selecting a path resides in lookup-tables. The district court found the claims invalid as indefinite under 35 U.S.C. 112. The Federal Circuit reversed. The terms “processing system” does not prevent the claims, read in light of the specification and the prosecution history, from informing those skilled in the art about the scope of the invention with reasonable certainty. View "Cox Commc'ns, Inc. v. Sprint Commc'n Co., LP" on Justia Law