Fresh From the Bench: Latest Federal Circuit Court Cases
CASE OF THE WEEK
PersonalWeb Technologies LLC v. Google LLC, Appeal Nos. 2020-1543, -1553, -1554 (Fed. Cir. Aug. 12, 2021)
In this week’s Case of the Week, the Federal Circuit affirmed a district court’s judgment on the pleadings that the claims of three patents owned by appellant PersonalWeb were invalid as patent-ineligible under 35 U.S.C. § 101. The claims were generally directed to data processing methods wherein a substantially unique identifier is assigned to a data item based on the data item’s content, and upon receiving a request containing such an identifier, a computer would compare the content-based identifier to a plurality of values and perform various data management functions, such as granting or disallowing access to the item, retrieving the item, or marking the item for deletion.
Seabed Geosolutions (US) Inc. v. Magseis FF LLC, Appeal No. 2020-1237 (Fed. Cir. Aug. 11, 2021)
In an appeal from a final decision upholding patentability in an inter partes review, the Federal Circuit vacated and remanded, holding that the Patent Trial and Appeal Board erred in its construction of challenged claims of U.S. Reissue Patent No. 45,268 (“the ‘268 patent”). The ’268 patent was generally directed to seismometers for use in seismic exploration, and the challenged claims recited a “geophone internally fixed within [the] housing.” Based entirely on extrinsic evidence, the Board found that the term “fixed” had a special meaning in the art that limited the claim to “non-gimbaled” geophones, and determined based on that finding that the prior art did not disclose the geophone limitation. Petitioner Seabed appealed, arguing that the Board erred in its claim construction. The Federal Circuit agreed, explaining that the intrinsic evidence contained no discussion of gimbaled or non-gimbaled geophones, and that the Board erred both (1) in relying on extrinsic evidence given the clarity of the intrinsic evidence, and (2) in its construction of the challenged claims which was narrower than the broadest reasonable interpretation based on the intrinsic evidence alone.