829 F.3d 1353
Fed. Cir.2016Background
- Unwired Planet sued Apple for infringement of multiple patents; the district court granted summary judgment of non‑infringement for patents ’446, ’260, and ’831 and no indirect infringement for ’092; Unwired appealed.
- ’446 patent: claims a system where mobile devices send speech to a remote speech‑recognition server and receive a symbolic data file; dispute over whether “voice input” requires transmission over a "voice channel." Unwired accused Siri.
- ’260 patent: claims a provisioning method requiring "user information required to establish a user account" and a provisioning request containing that user information plus the user’s selection; Unwired accused Apple’s App Store/iTunes flow (X‑token, buyProduct request).
- ’831 patent: claims a secure transmission method using a wideband two‑way channel for handshake and a narrowband one‑way channel for encrypted data; Unwired accused Apple Push Notification Service (APNS).
- ’092 patent: claims collecting a plurality of device‑dependent location inputs; district court denied summary judgment of no direct infringement but granted no indirect infringement, reasoning Apple’s noninfringement defense was strong enough to preclude inducement/willful blindness findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Construction of “voice input” (’446) | "Voice input" means speech input; plain meaning does not require channel restriction | "Voice input" requires transmission over a voice channel; Siri uses TCP/IP (not a voice channel) | Reversed district court: "voice input" has plain meaning and does not require a voice channel; vacated summary judgment for ’446 |
| "User information" / provisioning (’260) | Hashed password in X‑token contains same user information and satisfies the claim; form does not matter | Hashed token is different from the original password and thus not the claimed "user information" | Vacated summary judgment for ’260; factual question whether hashed token contains the same user information for jury |
| "Narrowband channel" (’831) | APNS channel from app provider to device is narrowband because payload limits and overhead make it meaningfully lower bandwidth | APNS uses same TCP/IP channel (same bit rate) for handshake and push—no separate narrowband channel | Affirmed summary judgment for ’831: no genuine fact issue; APNS does not meet the construed "narrowband channel" limitation |
| Indirect infringement knowledge (’092) | Apple knew or was willfully blind to underlying direct infringement by iOS devices | Apple’s strong noninfringement position shows no subjective knowledge or willful blindness | Vacated district court’s grant as to indirect infringement; district court erred by relying on objective strength of defense rather than Apple’s subjective knowledge; remand to resolve knowledge issue |
Key Cases Cited
- Thorner v. Sony Comput. Entm’t Am. LLC, 669 F.3d 1362 (Fed. Cir.) (claim construction and intrinsic‑record principles)
- Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576 (Fed. Cir.) (claims construed from intrinsic record; disavowal standard)
- Teleflex, Inc. v. Ficosa N. Am. Corp., 299 F.3d 1313 (Fed. Cir.) (clear and unmistakable disclaimer/disavowal requirement)
- Global‑Tech Appliances, Inc. v. SEB S.A., 563 U.S. 754 (willful blindness and knowledge requirement for induced infringement)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S.) (summary judgment standard)
- Acumed LLC v. Stryker Corp., 483 F.3d 800 (Fed. Cir.) (jury question on factual disputes bearing on infringement)