Thought, Inc. v. Oracle Corporation
698 F. App'x 1028
| Fed. Cir. | 2017Background
- The ’197 patent claims a middleware system that lets object-oriented applications access relational databases via interchangeable adapters and an abstraction layer.
- Claim 3 requires a first adapter to “extract[] the object attributes and the object name from the object” and pack them as data, and a second adapter to map metadata to data store content.
- Thought sued Oracle, alleging Oracle’s TopLink (specifically its find() method) infringed claims 1, 3, 5, 7, and 8; Oracle denied infringement and counterclaimed invalidity (later dismissed without prejudice).
- The district court construed “object” as an “instance of a class,” did not construe “extracting,” and granted summary judgment of noninfringement to Oracle based primarily on the “extracting” limitation.
- Thought’s theory: the find() method’s parameter set is an object from which the entityClass (object name) and primaryKey (object attributes) are extracted; Oracle argued the method merely passes references and does not extract a subset of data from a single object.
- The Federal Circuit affirmed, agreeing that “extracting … from the object” requires removing data from an object (leaving the container behind) and that the accused method does not extract both required pieces from a single object.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of “extracting the object attributes and the object name from the object” | Thought: “extracting” means simply “obtaining”; not limited to a subset | Oracle: “extracting” requires taking data out of the object (not copying the whole container) | Court: “Extracting … from” means removing data from its container (may include all contents but not the container itself); plain language and spec support this |
| Whether TopLink’s find() meets the extracting limitation (single-object requirement) | Thought: the method’s parameter set is a single object containing references to two objects; therefore extraction occurs from that single parameters object | Oracle: find() merely passes references and draws object name and attributes from separate objects, so it does not extract both items from one instance | Court: Claim requires extracting both items from a single object instance; Thought’s parameters-object (references to two objects) does not satisfy this; noninfringement affirmed |
Key Cases Cited
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (claim-context guides term meaning)
- Teva Pharm. USA, Inc. v. Sandoz, Inc., 135 S. Ct. 831 (2015) (review standard for claim construction—defer to subsidiary factual findings)
- Accenture Glob. Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336 (Fed. Cir. 2013) (regional circuit law governs grant/denial of summary judgment)
- JL Beverage Co., LLC v. Jim Beam Brands Co., 828 F.3d 1098 (9th Cir. 2016) (Ninth Circuit reviews summary judgment de novo)