Video Solutions Pte. Ltd. v. Cisco Systems, Inc.
2:23-cv-00222
| E.D. Tex. | May 14, 2025Background
- Cisco moved the court for "further claim construction" of the term "endpoint" in the '452 patent, seeking to add language clarifying that endpoints must be configured to capture videoconference data.
- The dispute centers on whether a media server can be considered an "endpoint" within the meaning of the patent claims, as proposed by Video Solutions.
- Magistrate Judge Payne had already construed "endpoint" as “a device or collection of devices, where data flow starts or ends, that connect to and exchange information over a computer network,” expressly rejecting Cisco’s argument that it could not include a server.
- Video Solutions filed objections to the original claim construction, while Cisco did not and instead defended the adopted construction.
- Cisco filed its motion for clarification four months after the district court adopted Judge Payne’s construction, and only weeks before the scheduled trial.
- The court denied Cisco’s motion as untimely and not raising a bona fide claim construction dispute, noting that the dispute concerned application of the construction, not the construction’s meaning itself.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Whether the court should revisit claim construction of "endpoint" | Construction should not be amended; motion untimely | Further construction/clarification needed due to case changes and infringement theory | Denied as untimely and waived; no new construction permitted |
| Whether "endpoint" must be configured to capture video data | No such requirement in claim language | Language necessary due to asserted patent's context | Court rejected; claim doesn't require all endpoints to capture data |
| Whether a media server can be an "endpoint" | Yes, under current construction | No, should be excluded based on further construction | Court did not resolve; factual issue under existing construction |
| Whether O2 Micro requires further construction at this stage | No, applies to scope, not application | Yes, duty to resolve the dispute before trial | Does not apply; this is an application issue, not construction |
Key Cases Cited
- O2 Micro Int’l, Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351 (Fed. Cir. 2008) (court must resolve fundamental claim construction disputes, not application of agreed construction)
- SanDisk Corp. v. Memorex Prods., Inc., 415 F.3d 1278 (Fed. Cir. 2005) (district courts have discretion to refuse untimely claim construction arguments)
- Nuance Commc’ns, Inc. v. ABBYY USA Software House, Inc., 813 F.3d 1368 (Fed. Cir. 2016) (dissatisfaction with adopted construction before trial does not require re-construction)