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Muniauction, Inc. v. Thomson Corp., 532 F.3d 1318, 87 U.S.P.Q.2d 1350

Facts

Muniauction, Inc. filed a lawsuit against Thomson Corporation alleging infringement of U.S. Patent No. 6,161,099, which pertains to electronic methods for conducting municipal bond auctions over the Internet using a web browser. The jury initially found that the claims were not obvious and awarded Muniauction approximately $77 million for lost profits due to Thomson's willful infringement. Thomson appealed the decision, arguing that the patent claims were obvious and that it did not infringe the claims under the appropriate standard for joint infringement.

Muniauction, Inc. filed a lawsuit against Thomson Corporation alleging infringement of U.S. Patent No. 6,161,099, which pertains to electronic methods for conducting municipal bond auctions over the Internet using a web browser.

Issue

Whether the claims of U.S. Patent No. 6,161,099 are obvious and whether Thomson infringed the patent.

Whether the claims of U.S. Patent No. 6,161,099 are obvious and whether Thomson infringed the patent.

Rule

Analysis

Conclusion

The court reversed the jury's finding of nonobviousness, concluding that claims 1 and 31 of the _099 patent are obvious as a matter of law.

The court reversed the jury's finding of nonobviousness, concluding that claims 1 and 31 of the _099 patent are obvious as a matter of law.

Who won?

The court ultimately ruled in favor of Thomson, reversing the jury's decision that the patent claims were not obvious and finding that Thomson did not infringe the remaining asserted claims. The court's analysis highlighted that the modifications to the prior art were predictable and that the evidence presented by Muniauction was insufficient to overcome the strong prima facie case of obviousness established by Thomson.

The court ultimately ruled in favor of Thomson, reversing the jury's decision that the patent claims were not obvious and finding that Thomson did not infringe the remaining asserted claims.

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