Amdocs (Israel) Limited v. Openet Telecom, Inc.
1:10-cv-00910
E.D. Va.Jan 22, 2013Background
- Amdocs (Israel) Limited sues Openet for alleged infringement of four related patents ('797, '984, '510, '065) concerning mediation, DRs, and billing in network services.
- Openet moves for summary judgment of non-infringement and invalidity; Amdocs moves for claim constructions and partial summary judgment of no invalidity and no inequitable conduct.
- The court granted parts of both motions in prior orders and now issues a memorandum opinion deciding infringement, claim construction, and inequitable conduct rulings.
- The patents claim a distributed hub-and-spoke architecture that processes network usage data close to the source, with data enhancement and field enhancements shaping DRs for billing.
- The '797 patent focuses on a single rolled-up record representing multiple services; the '065, '510, and '984 patents focus on DR collection, enhancement, and completion within a distributed framework.
- The court concludes Openet does not infringe any asserted claims, finds inequitable conduct in favor of Amdocs' counterclaims? (the court actually grants inequitable conduct in Openet’s favor), and dismisses invalidity claims without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legal standard for infringement at summary judgment | Amdocs contends it presents genuine infringement issues supported by evidence. | Openet argues no trial-worthy infringement evidence exists. | No genuine infringement issue; summary judgment for Openet on infringement. |
| Construction of 'enhance' and 'enhancement' in the '065 patent | Amdocs seeks data-enhancement meaning closely tied to dissemination of distributed processing. | Openet advocates field-enhancement-centered construction tied to GUI and specific field-level operations. | Court construed 'enhance' as applying a number of field enhancements in a distributed fashion; 'enhancement' as data-enhancement with field enhancements. |
| Construction of 'completing' in the '510' and '984' patents | Amdocs argues completion relates to finalizing DRs via enhancements. | Openet contends no special construction beyond ordinary meaning. | Court held 'completing' means enhancing to populate all required fields; completion requires enhancement to full DRs. |
| Construction of 'single record representing each of the plurality of services' in the '797 patent | Amdocs asserts a broad interpretation of a single record representing multiple services. | Openet argues for a rolled-up record incorporating all data fields. | Court construed to mean one record including customer usage data for each service; rolled-up interpretation rejected. |
Key Cases Cited
- Markman v. Westview Instrs., Inc., 517 U.S. 370 (1996) (claims construction is a matter of law)
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (intrinsic and extrinsic evidence limits on claim construction)
- Therasense, Inc. v. Becton, Dickinson & Co., 649 F.3d 1276 (Fed. Cir. 2011) (tightened standards for intent and materiality in inequitable conduct)
- Aventis Pharma S.A. v. Hospira, Inc., 675 F.3d 1324 (Fed. Cir. 2012) (but-for materiality standard in inequitable conduct analysis)
- Bell Atl. Network Servs., Inc. v. Covad Commc'ns Grp., Inc., 262 F.3d 1257 (Fed. Cir. 2001) (claim construction and ordinary meaning presumption)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (summary judgment standard and burden on movant to show no genuine issue)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard—absence of evidence shifts burden)
- Zoltek Corp. v. United States, 672 F.3d 1309 (Fed. Cir. 2012) (infringement requires in-country activity for 271(a))
- NTP, Inc. v. Research in Motion, Ltd., 418 F.3d 1282 (Fed. Cir. 2005) (infringement analysis for wireless patents)
- Ecolab, Inc. v. Paraclipse, Inc., 285 F.3d 1362 (Fed. Cir. 2002) (claim language and specification guide interpretation)
