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Keywords

defendanttrialmotionsummary judgmentpatentmotion for summary judgment

defendantpatent

Related Cases

Microsoft Corp. v. Commonwealth Scientific and Industrial Research Org., 572 F.Supp.2d 786, 2008 Markman 3854561

Facts

The Commonwealth Scientific & Industrial Research Organisation (CSIRO) sued Buffalo Technology for infringing its patent related to WLAN technology. The patent describes a system where multiple wireless transceivers communicate in environments where radio signals can take multiple paths due to reflections from walls and furniture, leading to potential interference. The parties disputed the construction of several claim terms, prompting the court to issue a claim construction opinion.

The specification states the problem the '069 Patent purports to solve relates to multipath interference, which affects the ability of the transceivers to communicate across a wireless channel.

Issue

What is the proper construction of the disputed claim terms in U.S. Patent No. 5,487,069, particularly 'confined multipath transmission environment of radio frequencies'?

The asserted claims contain the phrase 'confined multipath [transmission] environment [of radio frequencies].' CSIRO contends this phrase limits the claims and argues 'confined multipath [transmission] environment [of radio frequencies]' means 'an indoor environment.' Defendants contend the phrase 'confined multipath [transmission] environment [of radio frequencies]' does not limit the claims.

Rule

The court applies the principle that the claims of a patent define the invention, and claim terms are given their ordinary meaning as understood by someone skilled in the art at the time of the invention, considering the patent's intrinsic evidence.

It is a 'bedrock principle' of patent law that 'the claims of a patent define the invention to which the patentee is entitled the right to exclude.' Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed.Cir.2005) (en banc) (quoting Innova/Pure Water Inc. v. Safari Water Filtration Sys., Inc., 381 F.3d 1111, 1115 (Fed.Cir.2004)).

Analysis

The court analyzed the intrinsic evidence, including the patent's specification and prosecution history, to determine the meaning of the disputed terms. It found that the term 'confined multipath transmission environment of radio frequencies' should be construed as 'an indoor environment' based on the context provided in the specification and the prior claim construction in a related case.

The court adopted CSIRO's construction after a review of the specification and prosecution history to discern the term's meaning. However, the parties in Buffalo did not raise the issue as to whether the 'confined multipath [transmission] environment [of radio frequencies]' phrase is a claim limitation.

Conclusion

The court concluded that the disputed claim terms were to be construed in favor of the patentee, and the defendant's motion for summary judgment of invalidity was denied.

Thus, the term 'for [data transceiving] operation [by radio transmissions] … in a confined multipath [transmission] environment' results in a structural difference in the claimed transceivers and is an essential aspect of the invention.

Who won?

Commonwealth Scientific & Industrial Research Organisation (CSIRO) prevailed because the court adopted its proposed constructions of the claim terms, which supported the validity of the patent.

CSIRO argues 'confined multipath [transmission] environment [of radio frequencies]' means 'an indoor environment.' Defendants contend the term means 'an area in which surrounding surfaces contain transmitted signals and in which those signals arrive at a receiver by multiple paths.'

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