Facebook, Inc. v. Pragmatus AV, LLC (No. 2013-1350, 9/11/14) (Moore, O'Malley, Taranto)
September 11, 2014 6:30 PM
Moore, J. Although patent had not expired when it was before the Board, which therefore applied the broadest reasonable interpretation standard to claim construction, the Court construed the claims under Phillips because the patent had expired by the time of appeal. However, the Court's construction under Phillips was broader than the Board's construction, so the Board's construction was necessarily erroneous even under the broadest reasonable interpretation standard.
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Scientific Plastic Products v. Biotage AB (No. 2013-1219, -1220, -1221, 9/10/14) (Newman, Moore, Wallach) September 10, 2014 12:15 PM Newman, J. Affirming Boards rejection of claims as obvious in inter partes reexamination. The Board was correct in viewing cited art as "analogous" where art had the same purpose as the claimed invention. Moore, J., dissented. A full version of the text is available in PDF form. |
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Interval Licensing LLC v. AOL, Inc. (No. 2013-1282, -1283, -1284, -1285, 9/10/14) (Taranto, Chen) September 10, 2014 5:10 PM Chen, J. Affirming judgment that certain claims were invalid as indefinite, while reversing claim construction of other claims. Claim phrase "in an unobtrusive manner" that "does not distract a user" had "too uncertain a relationship to the patents' embodiments" to "provide a reasonably clear and exclusive definition." A full version of the text is available in PDF form. |
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EPOS Technologies, Ltd. v. Pegasus Technologies, Ltd. (No. 2013-1330, 9/5/14) (Bryson, Hughes) September 5, 2014 10:24 AM Hughes, J. Reversing summary judgment of non-infringement of claims to digital pens. The district court erred in construing claims to be limited to features of a preferred embodiment and, in one instance, construed claims to exclude the preferred embodiment. The district court also misapplied the all elements rule in finding no infringement under the doctrine of equivalents. A full version of the text is available in PDF form. |
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Buysafe, Inc. v. Google, Inc.. (No. 2013-1575, 9/3/14) (Taranto, Hughes) September 3, 2014 3:20 PM Taranto, J. Affirming judgment that claims directed to means for guaranteeing a party's performance of an online transaction were invalid under Section 101. A full version of the text is available in PDF form. |
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