Companies all over the world continue to use standard essential patents (SEPs) as an important part of their intellectual property strategy. In this article, we summarize recent SEP cases in U.S. Court of Appeals for the Federal Circuit (CAFC), district courts, the Patent Trial and Appeal Board (PTAB), and European courts.
3G Licensing, S.A. v. Honeywell Int'l. Inc. (CAFC)
In 3G Licensing, S.A. v. Honeywell Int'l. Inc. et al., No. 2023-1137, the Federal Circuit confirmed the PTAB's finding of unpatentability. The dispute centered around the construction of the term "Enhanced Absolute Grant Channel" ("E-AGCH"), a term used in 3G standards, and the priority date of the patent at issue. As to claim construction, the Federal Circuit affirmed the PTAB's finding that E-AGCH requires an absolute grant, as the word "absolute" appears in the term itself and such a construction is consistent with both the specification and extrinsic evidence. As to priority date, the Federal Circuit affirmed the PTAB's finding that the patent was not entitled to claim priority of an underlying Korean application because there is no record evidence that one of ordinary skill would have understood that application to disclose an E-AGCH. The Court thus affirmed.
In construing the term E-AGCH, the Court rejected 3G Licensing's argument that the E-AGCH used in the patent has a different meaning from that used in the 3GPP documents. The Court noted that extrinsic evidence, such as the 3GPP documents, showed that the word is a term of art with a commonly understood meaning in the industry, and 3G Licensing did not put forth any evidence of another accepted meaning of E-AGCH from other industry documents or patents. Thus, unless a term in a SEP patent has another commonly understood meaning in the industry or the patent shows clear intent to redefine the term, the term is likely found to have a meaning consistent with how it is used in the relevant standards.
Koninklijke Philips N.V. v. Quectel Wireless Sols. Co. Ltd. (CAFC)
In Koninklijke Philips N.V. v. Quectel Wireless Sols. Co. Ltd., No. 2023-1223, the Federal Circuit affirmed the PTAB's finding of a motivation to combine and rejection of the patentee's purported secondary indicia of non-obviousness. As to motivation to combine, the Court rejected the patentee's argument of no substantial evidence, finding that the Board's weighing of evidence including expert testimony was proper and supported by substantial evidence. As to secondary indicia, the Federal Circuit rejected the argument that the PTAB improperly rejected the patentee's evidence and found no error in the Board's finding that the evidence and its nexus to the claimed invention does not rebut Quectel's strong prima facie case. The Court thus affirmed.
In finding substantial evidence supporting the Board's motivation to combine, the Court noted conflicting expert testimony from the parties regarding the benefits and drawbacks of the implementation with the proposed combination. The Court noted that Philips presented no evidence questioning the legitimacy of the power saving benefit identified by Quectel's expert, and thus, has not shown the Board erred in relying on the expert testimony articulating specific benefits achieved by the implementation. The Court's decision shows that in presenting expert's testimony for motivation to combine, it would be helpful to present evidence showing that the other side's expert's testimony is illegitimate or questionable.
In its analysis of objective indicia of nonobviousness, the Court noted that "[a] claimed invention's adoption as part of an industry standard is certainly objective indicia of nonobviousness." While ultimately finding no error in the Board's conclusion that Philips' evidence of objective indicia of nonobviousness does not rebut Quectel's prima facie case, the Court's statement shows that the adoption of an invention in an industry standard could help to show nonobviousness of a SEP in certain cases.
Freedom Patents LLC v. Lenovo Group Limited et al. (E.D. Tex.)
On July 17, 2024, Freedom Patents, a non-practicing entity, filed a complaint against Lenovo Group Limited and Lenovo PC HK Limited (collectively, "Lenovo") for direct and indirect infringement of three patents (U.S. Patent Nos. 8,284,686, 8,374,096, 8,514,815). Freedom Patents alleges that Lenovo's laptops, tablets, and desktops infringe because they support 802.11ax communications, which are allegedly covered by the patents.
Freedom previously asserted the same patents in the same court against Cisco, ASUSTek, Hewlett Packard, LG, Micro-Star, Razer, Samsung, Sharp, Sony, T-mobile, and Vantiva in June 2024. Like the complaints against other defendants, while Freedom Patents relies on the 802.11ax standards for its infringement allegations, its complaint does not allege that the asserted patents are essential to them. Nor does it state that the three patents are subject to a commitment to license them on fair, reasonable, and non-discriminatory ("FRAND") terms.
On September 3, 2024, Freedom voluntarily dismissed its claims against Lenovo. Freedom also recently dismissed its claims against Cisco, Hewlett Packard, LG, Samsung, Sony, and T-mobile. As Freedom tends to settle its cases early, it remains to be seen whether any of its cases will evolve into the stage involving FRAND-related disputes.
General Video, LLC v. Acer Inc. (E.D. Tex.)
On August 30, 2024, General Video filed a complaint against Acer for direct and indirect infringement of six patents (U.S. Patent Nos. 6,584,443, 7,069,224, 7,225,282, 7,359,437, 9,036,010, 9,843,786), which were originally assigned to Matsushita Electric Industrial, Silicon Image, and Koninklijke Philips. General Video alleges that Acer's laptops, desktops, monitors, and graphics cards infringe because they support DisplayPort (DP) standards or embedded DP (eDP) standards promulgated by the Video Electronics Standards Association (VESA). On the same day General Video filed its complaint against Acer, it also filed complaints in the same court asserting the same patents against ASUSTek, Hewlett Packard, Dell, and Lenovo.
General Video alleges these patents are essential to DP standards or eDP standards, and each of these Patents is included among the pool of patents licensed and offered for license as part of the DP Patent Portfolio License (the "DP License") offered through Via Licensing. In addition, General Video alleges that, before July 29, 2016, MPEG LA, on behalf of General Video and its predecessors-in-interest, provided notice to Acer regarding the asserted patents and that Acer needed to be licensed under those essential patents. General Video alleges that Acer's infringement is willful and deliberate because of its prior knowledge of the asserted patents and essentiality to the DP or eDP standards.
As General Video alleges the asserted patents are essential to the DP or eDP standards, it may be obligated to license to ASUSTek the asserted patents on Reasonable and Non-Discriminatory (RAND) terms, as required by the VESA IPR policy. Via Licensing currently publishes its license rate as $0.2 per unit for the DP License. See https://www.via-la.com/licensing-2/displayport/displayport-license-fees/. ASUSTek may be able to argue that it should not pay a license rate higher than the published rate under the RAND terms.
Amazon.Com, Inc. and Amazon.Com Services LLC v. Nokia Technologies (PTAB)
On July 5, 2024, Amazon filed two IPR petitions (IPR2024-01139, IPR2024-01141) against Nokia, requesting review of U.S. Patent Nos. 6,950,469 and 8,036,273, which Nokia claims to be essential to the H.264 and H.265 video compression standards. Nokia is asserting the '469 and '273 patents against Amazon and its subsidiary Twitch in the District of Delaware.
In both petitions, Amazon relied on a standard document "Test Model Long Term Number 6" (TML6) as a primary reference, which is source code authored by the Video Coding Experts Group ("VCEG") of the International Telecommunication Union Telecommunication Standardization Section ("ITU-T"). Amazon argued that TML6 was available on a public VCEG FTP server prior to the priority date of the asserted patents, qualifying as a printed publication under pre-AIA 35 U.S.C. §102(a). Amazon heavily relied on testimony of its expert, Dr. Ramchandran, to explain functions of source code in TML6.
Interestingly, both the '469 and '273 patents were previously challenged in IPRs by Lenovo and were settled before the Board reached any institution decisions. Amazon's petitions relied on the same prior art as in the previous Lenovo IPRs. In the Lenovo IPRs, Nokia argued for discretionary denial under §325(d) as the TML6 reference was discussed in the patent specification and the other patent reference Fandrianto was cited on the face of the patent. Amazon argued in its petition that the patent's description lacks the detail in the TML6 reference and thus was not considered by the Examiner. Nokia likely will raise the same argument for discretionary denial of institution in its preliminary response.
AT&T Services Inc. et al. v. Innovative Sonic Ltd. (PTAB)
On July 19, 2024, AT&T Services Inc., T-Mobile USA, Inc., Verizon Wireless, Ericsson Inc., and Nokia of America Corporation ("Petitioners") filed an IPR challenging U.S. Patent No. 7,664,059, owned by Innovative Sonic Limited. The '059 patent is the subject of ongoing litigation in the Eastern District of Texas, where Innovative Sonic asserted the patent as essential to 3G mobile communication standards.
Petitioners relied on two 3GPP standard specifications in the prior GSM communication system (2G) as prior art anticipating and rendering the patent obvious. Petitioners cited the Penumbra, Inc. v. RapidPulse, Inc. (IPR2021-01466) decision to support their use of these references. The Penumbra decision held that a petitioner could rely on prior art references that were part of the technical standards of an industry, such as 3GPP, if those standards were widely accessible and recognized as prior art. Petitioners argue that both 3GPP specifications were publicly available at the relevant time and therefore qualify as valid prior art.
This IPR illustrates the importance of examining standards of systems of prior generation as potential prior art. As technology in systems of newer generation often evolves from prior generation systems, the standard specification in prior generation systems could potentially disclose the invention in the asserted SEP.
AT&T Services Inc. et al. v. Asus Technology Licensing Inc. (PTAB)
On July 25 and July 26, 2024, AT&T Services Inc., T-Mobile USA, Inc., Verizon Wireless, Ericsson Inc., and Nokia of America Corporation ("Petitioners") filed IPRs (IPR2024-01144, IPR2024-01142) challenging U.S. Patent Nos. 9,237,489 and 10,887,868, owned by Asus Technology Licensing Inc. In ongoing litigation, Asus asserts these patents against Petitioners, alleging infringement based on carrier aggregation technologies used in 5G and LTE networks.
In IPR2024-01144, Petitioners relied on proposals submitted from Nokia and Ericsson during the standards working group meetings as prior art. Petitioners also relied on several 3GPP 4G standard documents (TS36.331, TS36.300, TS.36.331 update) together as representing the state of art in telecommunications systems and referred to them collectively as a single reference in the invalidity grounds.
In IPR2024-01142, Petitioners relied on two U.S. patent references as prior art rendering the patent obvious, relying on the provisional filing date of the patent references. Both patent references are AIA patents (that is, patents filed on or after the date the relevant America Invents Act provisions became effective on March 13, 2013). Under the precedential PTAB decision in Penumbra, Inc. v. RapidPulse, Inc. (IPR2021-01466), an AIA patent can rely on the filing date of its priority application without showing that at least one claim is supported by the priority application. Citing the Penumbra decision, Petitioners provided cites to earlier provisional applications when asserting the claims elements are disclosed by the patent references, without showing any claim of the patent references is entitled to priority.
Juniper Networks, Inc. v. Monarch Networking Solutions LLC (PTAB)
On August 8, 2024 and August 26, 2024, the PTAB granted institution for an IPR petition Juniper filed against U.S. Patent Nos. 8,451,844 and 8,451,845, owned by Monarch. Monarch initially filed an infringement suit in the Eastern District of Virginia against Juniper in May 2023, claiming these patents are essential for MAP-E (Mapping of Address and Port using encapsulation), a mechanism for transporting IPv4 packets across an IPv6 network. The case was transferred to the Northern District of California in October 2023 and is currently stayed.
In both IPRs, the Board found that one of the grounds presented a reasonable likelihood of showing obviousness and therefore instituted all grounds in the IPRs. In its preliminary response, Monarch argued that the two references address completely different communication problems in the context of IP networks and therefore a person of ordinary skill would not have combined the references. The Board rejected Patent Owner's argument, citing Juniper's expert's declaration, and noted that even if the two references address completely different communication problems as Monarch argued, a person of ordinary skill would have still combined the references for the specific claim element at issue and expected success. The Board's decision shows that two references addressing different problems does not necessarily undermine the motivation to make the combination. See Cross Med. Prods., Inc. v. Medtronic Sofamor Danek, Inc., 424 F.3d 1293, 1323 (Fed. Cir. 2005) ("One of ordinary skill in the art need not see the identical problem addressed in a prior art reference to be motivated to apply its teachings.").
The Board was not convinced with the other grounds presented in the IPRs and left them for further developments at trial. In the ground relying on a document submitted to the staging folder IETF (Internet Engineering Task Force), the Board questioned the public accessibility of the document as to whether a person of ordinary skill exercising reasonable diligence could have located the document. In another ground asserting obviousness over a single reference, the Board was not convinced with Juniper's argument of simultaneous invention as Juniper does not explain how the evidence demonstrates simultaneous invention of all the limitations recited in the challenged claims.
AT&T Mobility LLC et al. v. Daingean Tech. Ltd. (PTAB)
On August 14, 2024, the PTAB denied institution for an IPR petition AT&T Mobility LLC, AT&T Services Inc., Ericsson Inc., Nokia of America Corporation, and T-Mobile USA, Inc. ("Petitioners") filed against U.S. Patent No. 10,484,976, owned by Daingean Technologies Ltd. Daingean filed an infringement suit in the Eastern District of Texas (EDTX) against AT&T in March 2023, asserting six patents including the '976 patent, and later voluntarily dismissed its infringement claims as to the '976 patent in August 2024. Daingean alleges the asserted patents is essential to the 5G wireless communication standards.
The Board denied institution of the IPR because the petition fails to show disclosure of a first RNTI phrase under the Board's construction. The Board faulted Petitioners for implicitly adopting a different construction of the first RNTI phrase but not providing any reason to adopt that construction. The Board noted that Petitioners recognized the potential dispute that the prior art reference does not disclose the first RNTI phrase under the Board's construction, but Petitioners made no attempt to show that the prior art reference discloses the Board's construction. The Board then decided that Petitioners did not make a sufficient showing for the first RNTI phrase under the Board's construction. The Board's decision illustrates the importance of addressing an anticipated claim construction dispute rather than just implicitly adopting it in the petition. To increase the chance of instituting the IPR, Petitioner should provide explanations in the petition why its proposed construction should be adopted and, if possible, showings that the prior art reference discloses or renders obvious the claims even if the other construction is adopted.
InterDigital v. Lenovo (UK Court of Appeal)
On July 12, 2024, the UK Court of Appeal delivered its judgment in InterDigital v Lenovo. The appeal (with grounds appealed by both parties) concerned the amounts payable by Lenovo for a license on fair, reasonable and non-discriminatory terms of InterDigital's portfolio of patents which have been declared essential ETSI 3G, 4G and 5G standards. It should be noted that the appeal panel included the very experienced patents judges Lord Justice Arnold and Lord Justice Birss.
The Court of Appeal upheld the decision that national limitation periods (e.g., six years in the UK and many other jurisdictions) are irrelevant in the assessment of FRAND terms. At first instance, the High Court ordered Lenovo to pay a lump of $138.7 million for a licence covering sales in the period 2007-2023. It held that an implementer such as Lenovo requires a licence from the first day it implements the relevant standards. This is because an implementer should not be rewarded for delay, whether the delay is the fault of the implementer or not. The Court pointed to the ETSI Guide and FAQs page which make it clear that a willing licensee would not wait for demands from SEP owners, but would pro-actively contact SEP owners, and would put money aside for the payment of royalties The Court noted that in the event of truly egregious conduct by a SEP owner, it can impose other sanctions such as denying or reducing interest and costs sanctions.
The Court of Appeal adjusted the royalty rate upward from $0.24 per unit to $0.30 per unit for past and future sales. At first instance, the only licence which the High Court found to be comparable was LG 2017. It used the blended rate of $0.24 per unit, then applied an adjustment ratio (which considers real world market values and other distinctions between LG and Lenovo) of 0.728 to reflect the characteristics of Lenovo's sales, resulting in a figure of $0.175 per unit. The Court of Appeal determined $0.24 per unit was too low considering a number of non-FRAND factors, however that InterDigital's proposed rate of $0.61 would be too high. The Court of Appeal found $0.30, although imprecise, as the next highest logical figure to arrive at moving upwards a modest amount from LG 2017, taking account of all the inherent uncertainties. The Court of Appeal also determined that the adjustment ratio should be revised to a ratio of 0.75. As a result of these revisions, the Court of Appeal calculated a pre-interest lump sum royalty of $178.3 million. This is a 28.5% increase from the royalties determined at first instance and whilst more favorable to Interdigital, it remains lower than the original $388.5 million it had sought.
Following the UK judgment, on October 9, 2024 Interdigital and Lenovo announced their agreement to enter into a new license agreement, with final terms to be determined in binding arbitration. It is likely that the guidance from the UK judgment will have assisted the parties in coming to such a decision, which includes the agreement to settle all pending litigation between them. This latest development highlights the role of alternative dispute resolution methods in allowing parties to withdraw from SEP litigation proceedings.
Panasonic v. Orope/Guangdong OPPO (UPC)
In the Panasonic v. Orope/OPPO patent infringement dispute regarding EP 2 568 724 ("radio communication device and radio communication method" allegedly relating to the 4G wireless standard) the Mannheim Local Division issued another order (docket no. UPC_CFI_210/2023, decision no.: ORD_33376/2024) on July 9, 2024, clarifying further confidentiality issues.1
Panasonic sought protection for confidential information under R. 262A RoP, contained in its reply as well as information from ongoing licensing negotiations between the parties. The court clarified that confidential information can still be protected under R. 262A RoP even if the opposing party has knowledge of it. It argued that such a confidentiality order aims to prevent further dissemination. However, the court did not agree with Panasonic that the general history of the license negotiations between the parties are to be fully protected under R. 262A RoP. Redacting such information of the negotiation history (e.g. timing when claim charts were submitted) is generally not possible in an unrestricted manner due to the publicity of the UPC registry and the fact that the legal understanding of a court decision requires certain context of facts. On the other hand, specific correspondence between the parties during their licensing negotiations, may be fully protected under R. 262A RoP.
Additionally, the court upheld the right to request confidentiality protection even though a Non-Disclosure Agreement (NDA) was already in place. The court reasoned that the UPC can impose enforceable penalty payments in the contracting member states and unlike other jurisdictions (e.g. Germany) there is no statutory limit on the maximum amount. This reason strengthens the protection of confidential information compared to an NDA (despite penalty provisions in the NDA in case of a breach). Furthermore, a confidentiality request also aims to prevent third-party access to sensitive documents in case the UPC allows a third-party access to the court files.
Further, the court denied Panasonic's request limiting access to confidential information to just one person on the side of Orope/OPPO and ruled that at least three individuals should have access. The rationale was based on the complexity of the proceedings and global reach of the dispute between the parties as well as due to practical reasons — if only one person were permitted to access the information and became unavailable (due to illness, vacation, etc.), the ability of Orope/OPPO to prepare their defense would be compromised.
Lastly, the court emphasized that access to confidential information by the representatives of the parties is to be granted exclusively to those representatives who may represent the parties in the specific UPC proceedings. In that regard the court denied OPPO's request to extend access of confidential information to legal representatives involved in parallel proceedings in other jurisdictions. The court argued that sharing information with external counsels, particularly those operating under different legal frameworks - like the UK which is not a member state of the UPC - would make it difficult to enforce confidentiality obligations and could lead to uncontrolled dissemination of sensitive information. The Mannheim Local division explicitly distances itself from an order of the Munich Local Division (order from 3 July 2024, UPC_CFI_471/2023 ORD_33986/2024) in which access was granted to representatives of the parallel UK proceedings.
However, the court clarified that coordination between legal teams involved in other parallel proceedings within other UPC Local Divisions may be granted but strictly limited to the purposes of conducting the parallel proceedings before the UPC. The court emphasized that any information shared in these cases could not be extended to national courts.
The present order shows that applications for secrecy protection are of great importance before the UPC, particularly in the context of SEP litigation since such disputes regularly extend beyond one jurisdiction. Parties before the UPC should be aware of confidentiality orders which may not be in line with secrecy protection in parallel proceedings outside of the UPC territory between the same parties.
Dolby International v. HP (UPC)
In the Dolby v. HP patent infringement proceeding regarding EP 3 490 258 ("method and recording medium storing coded image data") the Dusseldorf Local Division issued another order on 22 July, 2024, regarding access to confidential information (docket no. UPC_CFI_457/2023, order no. ORD_25519/2024).
Following the court's initial confidentiality order2 allowing Access Advance LLC (administering the patent pool including Dolby's HEVC-essential portfolio) to intervene in the proceedings in support of Dolby, under R. 313 RoP, the HP sought to limit access to confidential information on the side of the intervener Access Advance only to its legal representatives, excluding all other of its employees.
The court, however, found that limiting the access merely to the intervener's legal representatives was incompatible with its role as an intervener in the proceedings. As an intervener Access Advance must be treated equally like a party under R. 315 RoP, which includes the right to access confidential information under R. 262A.6 RoP. Specifically, the court affirmed that Access Advance is entitled to extend access to at least one natural person, in addition to its legal representatives (like any other party of the proceedings). Consequently, the court allowed access to a limited group of employees of Access Advance.
The present order underscores the status of the intervener being treated as a party, thus granting it equal rights regarding access to confidential information. Additionally, patent pool administrators intervening in the proceedings, may be more inclined and confident to share relevant (confidential) information in support of the party, knowing that such information may be fully protected under R. 262A RoP and that the intervener has the same rights as the main party in that regard.
NEC Corp. v. TCL (UPC)
NEC Corporation filed a patent infringement action against TCL Deutschland and six affiliated entities before the Munich Local Division (docket no. UPC_CFI_498/2023; order no.: ORD_41183/2024). The proceeding concerns EP 3 057 321 ("video decoding device, video decoding method, and program"). The Defendants filed a confidentiality request regarding specific details in their FRAND counterclaim and statement of defense.
In its order issued on August 14, 2024, the court highlighted that the number of persons having access to confidential information shall not be greater than it is necessary to ensure that the rights of the parties to a fair trial are respected. Therefore, the number of representatives granted access to the confidential information should not be "unlimited "or "indeterminable". This prevents unrestricted or indeterminate access, ensuring those responsible for maintaining confidentiality are clearly identified and liable for any breaches of a confidentiality order.
Against that background, the court granted access to NEC's representatives named in the statement of claim. Further, to not restrict NEC's right to choose its legal representatives, the court has also granted these representatives the right to share the relevant information with their team working on the case, provided they ensure confidentiality.
However, NEC's further request to grant access to four yet unnamed external experts was denied. While a party has the right to engage experts, this does not mean that all external experts selected by the party must automatically have access to confidential information. The number of experts granted access to the confidential information should not be "unlimited" or "indeterminable". Effective protection of confidential information requires clear accountability. It must be certain who is obliged to maintain confidentiality and who can be held responsible. Granting access 'in advance' is deemed inappropriate. The court ruled that once experts are appointed, NEC may further specify its request.
With the present order the court further established guidelines on how confidentiality requests are to be treated considering the number of individuals having access to confidential information. Parties must be prepared to specifically name those individuals.
TCT v. Philips Germany (German Federal Court of Justice)
On July 30, 2024, the German Federal Court of Justice granted a third-party request for access to court files in pending nullity appeal proceedings (docket no.: X ZR 56/23). The first instance nullity proceedings concerned EP 2 950 544 ("adaptive coding of the prediction error in hybrid video coding"). The German Federal Patent Court declared the disputed German part of the European patent invalid on November 25, 2022 (docket no.: 2 Ni 5/21 (EP) and 2 Ni (42/21 (EP)). An appeal against the decision of the German Federal Patent Court is still pending.
According to Section 99 (3) in conjunction with Section 31 (1) of the German Patent Act, third-parties are generally entitled to inspect case files of nullity proceedings in case of a legitimate interest. A party objecting to the inspection of files must demonstrate an opposing interest worthy of protection. In the present case the nullity plaintiff opposed the request of the third-party, arguing that the case involved questions of standard essentiality and reasonable license terms (FRAND), for which confidentiality orders had been issued in a parallel infringement proceeding. However, the nullity plaintiff failed to sufficiently demonstrate why granting access to the third-party would violate its confidentiality interests. Merely generic statements in that regard are not sufficient.
Obtaining access to court files in German nullity proceedings is thus easier than accessing files from UPC or German patent infringement proceedings. While the third party may substantiate a legal interest in obtaining access to the court files without a high threshold, the opposing party must demonstrate and substantiate an opposing interest worthy of protection and identify the documents and information that are covered by such interest. Simply referring to already granted confidentiality orders in parallel infringement proceedings is not sufficie
Footnotes
1. We covered the first confidentiality order on the production of licensing agreements issued by the Mannheim Local Division between the same parties in our Finnegan blog June 2024 edition https://www.finnegan.com/en/insights/articles/recent-filings-and-decisions-for-standard-essential-patents-sep-april-2024-us-district-courts-ptab-and-european-courts.html.
2. Also covered in our Finnegan blog June 2024 edition https://www.finnegan.com/en/insights/articles/recent-filings-and-decisions-for-standard-essential-patents-sep-april-2024-us-district-courts-ptab-and-european-courts.html.
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