Justia Patents Opinion Summaries

The Ibormeith patent, entitled “Sleepiness Detection for Vehicle Driver or Machine Operator,” concerns the monitoring a vehicle driver’s sleepiness and issuing a warning to the driver. The monitor disclosed in the patent may take into account factors including natural body-clock (circadian) rhythm, the magnitude and number of corrective steering actions the driver takes, cabin temperature, monotony of the road, and how long the driver has been driving. Some factors involve actions or conditions at the moment, like steering and light conditions, which are measured by sensors in the vehicle. Others involve general or driver-specific background information, such as circadian rhythm or a driver’s recent sleep patterns and alcohol consumption, which must be input by other means (the programmer or driver). The factors are weighted, according to contributory importance, and combined in a computational decision algorithm or model, to provide a warning indication of sleepiness. The claims at issue contain a “computational means” element that is subject to 35 U.S.C. 112(f). Ibormeith sued Mercedes for infringement. Mercedes argued that the means-plus-function “computational means” limitations in two independent claims were indefinite. The district court entered summary judgment in favor of Mercedes. The Federal Circuit affirmed, noting that the specification does not contain an algorithm that adequately provides structure for the claimed functions. View "Ibormeith IP, LLC v. Mercedes-Benz USA" on Justia Law

The patent examiner rejected claims in an application directed to a bone screw with a shank that is easy to produce and eliminates the need for an additional element to avoid splaying. The Patent Trial and Appeals Board affirmed. The Federal Circuit vacated on the basis that the examiner and the Board stated different grounds for rejection. View "In re Biedermann" on Justia Law

The district court entered summary judgment that Sturm, a manufacturer of cartridges for brewing single servings of coffee, did not infringe Keurig’s patents covering single-serving coffee makers and cartridges for the machines. The court concluded that exhaustion of Keurig’s patent rights was triggered by its sale of a patented item that completely practiced the claimed invention and that its claims were not saved by the fact that a consumer could use non-Keurig cartridges in a Keurig brewer in a noninfringing way. The Federal Circuit affirmed. View "Keurig, Inc. v. Sturm Foods, Inc." on Justia Law

ARRIS and SeaChange provide video-on-demand products and services. ARRIS owns the 804 patent, which discloses a media server capable of transmitting multimedia information over any network configuration in real time to a client that has requested the information, allowing a user to purchase videos that are then streamed to a device such as a television. ARRIS alleged infringement by SeaChange’s Interactive Television. A jury returned a verdict in ARRIS’s favor, finding willful infringement. The Federal Circuit affirmed the verdict and the district court’s decision to enhance the damages award. The district court then permanently enjoined SeaChange from selling products that infringe the 804 patent. SeaChange released a system that it claims is outside the scope of the 804 patent. The district court found that ARRIS failed to prove contempt by clear and convincing evidence. The Federal Circuit affirmed. View "nCUBE Corp. v. Seachange Int'l, Inc." on Justia Law

Intellect’s patents involve wireless transmission of caller identification information and disclose providing caller ID information from a message center to a personal communication device, such as a cell phone, by a wireless network and displaying the caller ID information on the cell phone’s screen. Intellect sued HTC for infringement. After a bench trial, the district court held the asserted patents unenforceable due to inequitable conduct by the inventor, Henderson, who falsely asserted that the invention had been reduced to practice. The Federal Circuit affirmed, holding that Henderson’s explanations were not credible in light of a pattern of deceit. View "Intellect Wireless, Inc. v. HTC Corp." on Justia Law

The patent concerns digital communication systems with data transceivers capable of receiving multiple, analog, high-speed, serial data signals. Once received, the analog data signal must be converted into a digital signal through a process called “sampling” that involves measuring the amplitude of the analog signal at precisely timed intervals to extract the data carried in the analog signal. The receiver needs a way to discern the proper rate at which to sample the analog signal and a means for generating a sampling signal with the appropriate frequency. When data is sent through cables over long distances, the incoming signal frequency can vary. To compensate for variances, receiver circuits adjust the sampling signal to match the frequency and phase of the incoming data signal. The district court held that Emulex infringed the patent. The Federal Circuit affirmed, holding that the patent would not have been obvious at the time of invention and that the district court properly exercised its discretion in granting a permanent injunction with a well-crafted sunset period.View "Broadcom Corp. v. Emulex Corp." on Justia Law

In 2010, Microsoft filed a complaint in the U.S. International Trade Commission, alleging that Motorola had violated the Tariff Act of 1930, 19 U.S.C. 1337, by importing mobile phones and tablets that infringe several Microsoft patents. The Commission instituted an investigation and, after an evidentiary hearing, the ALJ found that the accused Motorola products did not infringe the 054, 762, 376, or 133 patents and that Microsoft had failed to prove that the mobile devices on which it relied actually implemented those patents. The Commission upheld the ALJ’s findings, finding that Microsoft failed to prove that the Microsoft-supported products on which it relied for its domestic-industry showing actually practiced the patents. The Federal Circuit reversed in part, first affirming that Motorola does not infringe the 054 patent and that Microsoft failed to prove that a domestic industry exists for products protected by the 762 and 376 patents. With respect to the 133 patent the Commission relied on incorrect claim constructions in finding no infringement, the only basis for its finding no violation, for the main group of accused products. The court affirmed the noninfringement finding for the accused alternative design. View "Microsoft Corp. v. Int'l Trade Comm'n" on Justia Law

TecSec’s 702, 452, and 781 Patents derive from a common parent application and disclose a system and a method for providing security in a data network by nesting encrypted objects into other objects which are also encrypted, allowing a system to employ different security levels to restrict access to specific compartments of data. The district court found no infringement. The Federal Circuit reversed in part, holding that the court correctly construed the term “multi-level multimedia security,” but incorrectly limited the encrypted data to objects in multimedia form. The court also erred in holding that the term “digital logic means” was a means-plus-function limitation. TecSec may be able to prove infringement against every defendant except PayPal. View "TecSec, Inc. v. Int'l Bus. Mach. Corp." on Justia Law

Rexam, Valois, and MWV compete in the perfume packaging industry. Each sells spray pumps to fragrance houses such as Estee Lauder and Chanel. MWV developed an “invisible” tube that appears to disappear when immersed in liquid, enhancing the aesthetic appearance of the perfume bottle. The inventors needed a transparent material with a refractive index close to that of the perfume liquid. In 2003, Daikin, a plastics supplier, began promoting the fluoropolymer EFEP, a highly transparent fluoropolymer with a refractive index in the correct range. The inventors experimented with EFEP, but the original tubes were hazy and brittle. They tried different production techniques, including a quenching process and eventually developed the NoC® tube. In 2005, they filed patent applications and MWV began marketing the tube. Rexam obtained and analyzed a sample, obtained EFEP, and launched its invisible tube. The district court entered summary judgment of nonobviousness; denied summary judgment of indefiniteness; denied of Rexam’s motion to exclude expert testimony; and found, after trial, infringement of certain MWV patent claims. The Federal Circuit vacated the judgment of nonobviousness, but affirmed the claim constructions, denial of the motion to exclude, and findings of infringement. Rexam and Valois waived their indefiniteness arguments by failing to pursue them at trial. View "MeadWestvaco Corp. v. Rexam Beauty & Closures, Inc." on Justia Law

Sunovion owns the rights to the patent, which is directed to pharmaceutical compositions of the single-enantiomer drug eszopiclone, the active ingredient in the chiral drug marketed as a sleep medication with the brand name Lunesta®. The district court held, on summary judgment, that Dr. Reddy’s Laboratories did not infringe certain claims in that patent. The Federal Circuit reversed. Although the district court did not err in construing the claim term “essentially free” as containing less than 0.25 percent levorotatory isomer, Sunovion was entitled to a judgment of infringement as a matter of law under 35 U.S.C. 271(e)(2)(A). A generic manufacturer’s “certification” pledging not to infringe cannot override the conclusion that when a drug manufacturer seeks FDA approval to market a generic compound within the scope of a valid patent, it is an infringement as a matter of law. View "Sunovion Pharm., Inc. v. Teva Pharm. USA, Inc." on Justia Law