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Keywords

damagesinjunctionappealtestimonysummary judgmentpatentadmissibility
damagestestimonysummary judgmentpatent

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Apple Inc. v. Motorola, Inc., 757 F.3d 1286, 110 U.S.P.Q.2d 1695, 94 Fed. R. Evid. Serv. 301

Facts

In a patent infringement dispute, Apple Inc. and Next Software, Inc. filed a complaint against Motorola, Inc. and Motorola Mobility, Inc. asserting infringement of multiple patents related to smartphone technology. The case was initially filed in the Western District of Wisconsin but was later transferred to the Northern District of Illinois. The district court conducted claim construction and granted summary judgment of non-infringement for certain claims, excluding most expert testimony regarding damages. Both parties appealed the decisions regarding claim construction, admissibility of expert testimony, and the summary judgment ruling.

Issue

Whether the district court correctly construed the patent claims and whether it properly granted summary judgment of non-infringement and excluded expert testimony on damages.

Whether the district court correctly construed the patent claims and whether it properly granted summary judgment of non-infringement and excluded expert testimony on damages.

Rule

Analysis

The appellate court found that the district court erred in its claim construction by incorrectly applying means-plus-function analysis to certain limitations that did not use the term 'means.' The court emphasized that the absence of 'means' creates a strong presumption against means-plus-function interpretation. The appellate court concluded that the claims in question did convey sufficiently definite structure, thus reversing the district court's summary judgment of non-infringement.

In this case, as we find that the claims connote sufficiently definite structure to a person of ordinary skill in the art, we do not reach the second step of the means-plus-function analysis.

Conclusion

The appellate court affirmed in part, reversed in part, and vacated the district court's summary judgment ruling, allowing for further proceedings regarding damages and the injunction.

We also reverse the district court's grant of summary judgment of no damages for infringement of Apple's patents.

Who won?

The appellate court's decision to reverse the district court's summary judgment on non-infringement effectively favored Apple, allowing them to pursue their claims further. The court's ruling indicated that the district court had misapplied the law regarding claim construction and the admissibility of expert testimony, which could potentially lead to a different outcome in the damages phase of the case.

The appellate court's decision to reverse the district court's summary judgment on non-infringement effectively favored Apple, allowing them to pursue their claims further.

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