MySpace, Inc. v. GraphOn Corp.
756 F. Supp. 2d 1218
N.D. Cal.2010Background
- MySpace and Craigslist sue Graphon for patent infringement concerning user-controlled, password-protected online content publication.
- Patents at issue are Nos. 6,324,538; 6,850,940; 7,028,034; 7,269,591, all priority 1995.
- Plaintiffs argue the Mother of all Bulletin Boards (MBB) from 1993-1994 anticipates/obvious-lifies the claims.
- MBB stored entries in a hierarchical structure via a file system, and used a database-like management approach.
- Court held Plaintiffs’ motion for summary judgment valid; Defendant’s motion to strike McBryan opinions denied.
- The court performs claim construction and addresses whether 'database' and related terms cover non-relational databases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether MBB anticipates the asserted claims. | MBB discloses user-controlled database entries with IDs. | MBB is a file system, not a database. | Anticipated by MBB; issues of fact resolved in Plaintiffs’ favor. |
| Whether 'database' is limited to relational databases. | 'Database' includes various kinds with a structure. | Database means relational database only. | Court adopts broader, structured database construction. |
| Whether 'image' is non-textual content. | Image may be non-textual; specification supports broader. | Image must be non-textual content (binary). | Image construed as non-textual content representing graphics. |
| Whether 'transaction ID' is unique for a database entry. | MBB assigns unique IDs per entry. | File systems cannot use transaction IDs. | Transaction ID defined as a unique identifier for a database entry. |
| Whether 'password protecting' is obvious/valid. | Password-protection for entries is known art. | Password protection is old and obvious. | Password protecting is obvious/valid as prior art. |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claims must be read in light of intrinsic evidence; specification is primary source)
- In re Gleave, 560 F.3d 1331 (Fed. Cir. 2009) (anticipation requires disclosure of all claimed elements)
- Teleflex, Inc. v. Ficosa North America Corp., 299 F.3d 1313 (Fed. Cir. 2002) (claim terms interpreted in light of specification and prosecution history)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir. 1996) (intrinsic evidence is most significant source of meaning of disputed term)
- Altiris v. Symantec Corp., 318 F.3d 1363 (Fed. Cir. 2003) (limitations from the specification should not be read into claims absent clear intent)