MobileMedia Ideas, LLC v. Apple Inc., No. 2014-1060, -1091, 2015 U.S. App. LEXIS 4185 (Fed. Cir. Mar. 17, 2015) (Chen, J.). Click Here for a copy of the opinion.
MobileMedia filed suit against Apple in the District of Delaware asserting infringement of sixteen patents by various Apple products. Following summary judgment as to several patents, MobileMedia went to trial on claims from four patents (the '078, '075, '068, and '231 patents). Apple argued that its accused iPhone products did not infringe the asserted claims, and also argued that the claims are invalid as obvious under to 35 U.S.C. § 103. Following trial, the district court found claim 73 of the '078 patent and claim 23 of the '068 patent are valid and infringed. Three claims of the '075 patent were held invalid and not infringed, and two claims of the '231 patent were not infringed. Apple appealed the validity and infringement determinations, while MobileMedia cross-appealed the invalidity and non-infringement determinations. The Federal Circuit reversed the district court's decision that Apple infringed claim 73 the '078 patent, reversed the determination that claim 23 the '068 patent was valid, affirmed that the claims of the '075 patent are invalid, and vacated the determination that the claims of the '231 patent were not infringed, based on an erroneous claim construction.
With respect to claim 73 of the '078 patent, the Federal Circuit held that the district court construed the means-plus-function claim pertaining to mobile phone cameras too broadly. Specifically, the iPhone cameras do not have internal memory and therefore do not infringe the '078 claim limitation requiring "means for processing and for storing" data. Accordingly, no reasonable jury would have found Apple's technology infringing.
As to the '075 patent, directed toward rejecting incoming calls, the Federal Circuit affirmed that the claims were obvious in light of protocols developed by the European Telecommunications Standards Institute that implement the Global System for Mobile communications (GSM) standard. As a result, the Federal Circuit did not reach MobileMedia's appeal on non-infringement.
The Federal Circuit also found that several method claims from the '068 patent are obvious and invalid. These claims are directed to sending and receiving calls based on a one button activation. This was found to be a common-sense evolution of preexisting technology that required use of at least two selections to initiate or receive a call.
The Federal Circuit found the district erred in its claim construction of terms in the '231 patent, directed toward silencing alerts for incoming calls ("call alerts"). The district court construed "to change a volume of the generated alert sound" as meaning "to alter the degree of loudness of the alert sound that is being generated without cutting off the telephone circuit." This alteration of volume did not include "stop[ing]" the sound. Apple's products do not allow changing the volume of alerts and only allow a user to stop the sound. However, the Federal Circuit found support in the specification for a construction that includes both stopping and reducing the volume of alerts. Based on the new claim construction, the Federal Circuit vacated the non-infringement decision and remanded for further proceedings.
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