Search Team

Search by Last Name
A
B
C
D
E
F
G
H
I
J
K
L
M
N
O
P
Q
R
S
T
U
V
W
X
Y
Z

Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc.

Claims for Mobile Phone Display Interfaces Held Non-Abstract

Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., 2018 WL 542672 (Fed. Cir. Jan. 25, 2018) (MOORE, O’Malley, Wallach (concurring-in-part, dissenting-in-part) (E.D. Tex.: Gilstrap) (2 of 5 stars)

Fed Cir affirms judgment of liability for infringement. The opinion addresses three grounds of appeal.

Subject-matter eligibility: The district court did not err in denying LG’s motion for summary judgment of subject matter ineligibility for various claims in two Core Wireless patents relating to display interfaces for mobile telephones. Core Wireless’s claims were non-abstract per Alice step one because they were not directed to the “generic idea of summarizing information,” as LG argued, but were “directed to a particular manner of summarizing and presenting information in electronic devices.” Op. at 9.

Anticipation. The district court did not err in denying LG’s motion for JMOL of anticipation. The opinion notes that JMOL for the party carrying the burden of proof on invalidity is “reserved for extreme cases, such as when the opposing party’s witness makes a key admission.” Op. at 12. Reviewing the record, there was sufficient evidence to support the jury’s verdict of no anticipation. The opinion rejects LG’s contention that the entire basis for the district court’s decision was that the presumption of validity “saved” the claims in the face of unrebutted evidence.

Infringement. The district court did not err in denying LG’s motion for JMOL of no infringement. The district court did not err in its claim construction, though it was a “close case” based on the intrinsic record. The opinion discusses in detail the patent specification and the parties’ arguments, and concludes that there was no clear, unmistakable disclaimer that would limit the critical construction. The opinion also reasons that there was sufficient evidence in the record to support the infringement verdict.

Partial dissent: Judge Wallach would have held that the district court erred in claim construction, and would have remanded the infringement determination. His opinion discusses the specification and file history, and applies reasoning based on claim differentiation, and urges that even if Core Wireless did not disclaim its favored interpretation, the record better supported LG’s interpretation of what the claim meant.

KEYWORDS: SUBJECT-MATTER ELIGIBILITY (YES); ANTICIPATION (NO); INFRINGEMENT (YES); CLAIM CONSTRUCTION