Eon Corp. Ip Holdings LLC v. Silver Spring Networks, Inc.
815 F.3d 1314
| Fed. Cir. | 2016Background
- Eon sued Silver Spring for infringement of three patents relating to two-way interactive communication networks.
- A five-day trial found the asserted claims valid and infringed, awarding Eon $18.8 million, later reduced by the district court to $12.99 million after remittitur.
- The district court reversed the jury as to the '546 patent but upheld it as to the '101 and '491 patents, including the portable/mobile limitations.
- The district court held the terms 'portable' and 'mobile' to have plain and ordinary meaning, not requiring further construction.
- On appeal, Silver Spring challenges claim construction, infringement, and damages, arguing the terms should be construed, and that meters do not infringe; the majority reverses, finding no infringement under proper construction.
- The majority faulted the district court for not construing the terms and leaving scope to the jury; the dissent would have given portable/mobile their ordinary meaning and found infringement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court properly construed portable/mobile terms | Eon contends no construction was needed; plain meaning suffices. | Silver Spring argues the court must resolve scope for these terms and/or adopt Silver Spring’s special construction. | Court erred by not resolving scope; under proper construction, no infringement could be found. |
| Whether substantial evidence supports infringement under the correct construction | Eon asserts meters meet portable/mobile in the ordinary sense. | Silver Spring asserts meters are fixed and not portable/mobile under the patent context. | No reasonable jury could find infringement under the correct ordinary-meaning construction. |
| Remand vs. direct reversal for improper claim construction | Remand is necessary if construction is unresolved. | No remand needed; record shows noninfringement even with proper construction. | Remand not required; reversal appropriate due to lack of infringement under proper construction. |
Key Cases Cited
- O2 Micro Int’l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351 (Fed.Cir.2008) (court must resolve genuine claim-scope disputes; plain-meaning guidance may be inadequate)
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed.Cir.2005) (claims are given ordinary meaning in context and specification; not abstract meaning)
- Teva Pharm. USA Inc. v. Sandoz, Inc., 135 S. Ct. 831 (U.S. 2015) (court admissibility of claim construction under broader standard post-Teva)
- Trs. of Columbia Univ. v. Symantec Corp., 811 F.3d 1359 (Fed.Cir.2016) (claim construction requires context of the patent; not detached from specification)
- Summit 6, LLC v. Samsung Elecs. Co., 802 F.3d 1283 (Fed.Cir.2015) (district court may decline to construe if term is straightforward and clear)