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Interval Licensing LLC v. AOL, Inc., 766 F.3d 1364, 112 U.S.P.Q.2d 1188

Facts

Interval Licensing LLC (Interval) brought an action against AOL Inc., Apple Inc., Google Inc., and Yahoo! Inc. for patent infringement, claiming that the defendants infringed on its patents related to an attention manager designed to capture the peripheral attention of users near a display device. The United States District Court for the Western District of Washington found the patents invalid due to indefiniteness in the claim language. Interval appealed the decision, challenging the court's construction of key patent terms.

Interval Licensing LLC (Interval) brought an action against AOL Inc., Apple Inc., Google Inc., and Yahoo! Inc. for patent infringement, claiming that the defendants infringed on its patents related to an attention manager designed to capture the peripheral attention of users near a display device.

Issue

Whether the patent claims were invalid for indefiniteness and whether the district court's construction of the terms 'attention manager' and 'instructions' was correct.

Whether the patent claims were invalid for indefiniteness and whether the district court's construction of the terms 'attention manager' and 'instructions' was correct.

Rule

Analysis

The court analyzed the phrase 'unobtrusive manner that does not distract a user' and found it to be subjective and lacking objective standards, making it indefinite. The court noted that the specification did not provide clear guidance on how to interpret this phrase, leading to uncertainty about the scope of the claims. The court also reviewed the term 'attention manager' and determined that the district court's construction was too narrow, as it limited the definition to specific embodiments without considering the broader context of the invention.

Conclusion

The Court of Appeals affirmed the district court's judgment of invalidity for certain claims due to indefiniteness but vacated the judgment of non-infringement and remanded for further proceedings regarding the construction of 'attention manager' and 'instructions.'

Who won?

The prevailing party in this case is the defendants, as the Court of Appeals upheld the district court's finding of invalidity for the claims based on indefiniteness. The court's reasoning highlighted that the claim language failed to provide clear and objective standards, which is essential for patent validity. The defendants successfully argued that the terms used in the patent were too vague and subjective, leading to the conclusion that the claims could not be understood by those skilled in the art.

The prevailing party in this case is the defendants, as the Court of Appeals upheld the district court's finding of invalidity for certain claims due to indefiniteness.

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