Unwired Planet L.L.C. v. Google, Inc.
660 F. App'x 974
| Fed. Cir. | 2016Background
- Unwired Planet sued Google asserting multiple patents; three patents (’016, ’240, ’087) are at issue on appeal after district court claim constructions and invalidity rulings led Unwired to stipulate to noninfringement and the court to enter judgment.
- The district court construed several claim terms across the three patents and granted stipulated summary judgment of noninfringement based on those constructions; Unwired appealed those constructions and the invalidity (indefiniteness) ruling for two claims of the ’087 patent.
- The ’016 patent claims a server node that processes “network location information” to generate “marker information” and transmits mapping and marker data to a client to render a mobile-resource marker on a map.
- The ’240 patent claims a proxy server that enables communication between a wireless network (airnet) and a landnet, and includes user-account-related limitations used to push fleet data to mobile stations.
- The ’087 patent claims methods/apparatus for recursively displaying very large images on mobile-device screens by sending a reduced (smaller-dimension) image and permitting navigation into subareas; the district court held claims 17 and 31 indefinite for a preamble phrase describing the image as “much larger than” the screen.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of “marker information” (’016) | Marker info need only permit rendering (e.g., coordinates), not itself be a graphical rendering. | Marker info must be sufficient to render a graphical identifier. | Reversed district court: marker information need only permit rendering (adopts Unwired’s construction). |
| “Network location information regarding a mobile resource location” (’016) | Should mean information relating to location generally (could include GPS). | Must refer to location of device within a network (distinguishing GPS). | Affirmed district court: requires network-based location information (within a network). |
| “Server node” (’016) | A server node can be one or more computers or programs; does not require each computer to perform all functions. | Each computer in the server node must perform receiving, accessing, processing, and transmitting. | Reversed district court: server node is one or more computers or programs performing the claimed functions (no imported requirement that each computer perform every function). |
| “Proxy server” (’240) | Proxy server need not be limited to enabling communication between otherwise incompatible networks; could connect networks using same protocol. | Proxy server must enable communication between networks that otherwise could not communicate (i.e., performs mapping/translation). | Affirmed district court: proxy server enables communication between otherwise uncommunicative networks (mapping/translation functions implied). |
| “User account” (’240) | User account is any established account with a mobile-device user (not limited to carrier accounts). | User account refers to carrier-subscriber accounts as described in embodiments. | Reversed district court: adopt Unwired’s broader construction—an established account with a user of a mobile device (includes corporate accounts). |
| “Reduced image” (’087) | Reduced image = a version with smaller dimensions (may be cropped or decimated). | Reduced image must be an uncropped version with smaller dimensions. | Affirmed district court: reduced image means an uncropped version with smaller dimensions (not cropping). |
| “Key in the mobile device corresponding to a subarea in the reduced image” (’087) | Key means any button or touch input corresponding to a subarea. | Key means a physical or soft button/icon (not all touch inputs). | Affirmed district court: key is a button (physical or depicted/soft key) corresponding to a subarea. |
| Indefiniteness of claims 17 and 31 (’087) | Preamble phrase “an image having dimensions much larger than the dimension of the screen” lacks precision but only antecedent basis issue. | The phrase gives the claim essential limitation; without it claims are indefinite. | Affirmed: the preamble has patentable weight and renders claims 17 and 31 indefinite under §112; claims invalid. |
Key Cases Cited
- Info-Hold, Inc. v. Applied Media Techs. Corp., 783 F.3d 1262 (Fed. Cir.) (claim construction reviewed de novo; reliance on intrinsic evidence)
- Teva Pharm. USA, Inc. v. Sandoz, Inc., 135 S. Ct. 831 (U.S.) (district court factual findings about extrinsic evidence reviewed for clear error)
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir.) (claims read in context of specification; ordinary and customary meaning)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir.) (importance of intrinsic evidence in claim construction)
- Hill-Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367 (Fed. Cir.) (cannot import limitations from embodiments into claims)
- Proveris Sci. Corp. v. Innovasystems, Inc., 739 F.3d 1367 (Fed. Cir.) (when a term has patentable weight)
- Catalina Mktg. Int’l, Inc. v. Coolsavings.com, Inc., 289 F.3d 801 (Fed. Cir.) (preamble may supply essential limitations)
- Liebel-Flarsheim Co. v. Medrad, Inc., 358 F.3d 898 (Fed. Cir.) (claim-differentiation presumption between independent and dependent claims)
- Howmedica Osteonics Corp. v. Wright Med. Tech., Inc., 540 F.3d 1337 (Fed. Cir.) (inventor’s subjective testimony is irrelevant to claim construction)