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Keywords

damagesinjunctionappealmotionwillpatent
damagesappealwillpatent

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NTP, Inc. v. Research In Motion, Ltd., 418 F.3d 1282, 75 U.S.P.Q.2d 1763

Facts

NTP, Inc. owned several patents related to a method for enabling mobile users to receive email over wireless networks. The company sued Research in Motion, Ltd. (RIM) for patent infringement, claiming that RIM's BlackBerry system infringed on its patents. The case was heard in the U.S. District Court for the Eastern District of Virginia, where a jury found in favor of NTP, awarding damages and issuing a permanent injunction against RIM. RIM appealed the decision, challenging the jury's findings and the district court's claim constructions.

NTP ultimately asserted against RIM, and RIM was found to have infringed, sixteen system and method claims of five different patents owned by NTP.

Issue

Did the district court err in its claim construction and in finding that RIM's BlackBerry system infringed NTP's patents?

Did the district court err in its claim construction and in finding that RIM's BlackBerry system infringed NTP's patents?

Rule

Patent claim construction is a question of law reviewed de novo. The claims define the invention to which the patentee is entitled the right to exclude, and the words of a claim are given their ordinary and customary meaning as understood by a person of ordinary skill in the art at the time of invention. The court may consider the claims themselves, the specification, prosecution history, and extrinsic evidence to ascertain the meaning of claim terms.

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. The words of a claim are generally given their ordinary and customary meaning, which is the meaning that the term would have to a person of ordinary skill in the art in question at the time of the invention.

Analysis

The court analyzed the claim terms in question, including 'originating processor' and 'electronic mail system,' determining that the district court had erred in its construction of 'originating processor' but had correctly construed other terms. The court emphasized that the claims must be interpreted consistently across related patents. The analysis also involved comparing the properly construed claims to RIM's BlackBerry system to determine if infringement occurred.

The court must first correctly construe asserted claims, and then compare properly construed claims to allegedly infringing devices, systems, or methods. The district court's claim construction is reviewed de novo.

Conclusion

The Court of Appeals affirmed in part, reversed in part, and vacated in part the district court's judgment, concluding that while some claims were infringed, others were not.

We conclude that the district court erred in construing the claim term 'originating processor,' but did not err in construing any of the other claim terms on appeal.

Who won?

NTP, Inc. prevailed in the case, as the jury found that RIM's BlackBerry system infringed on multiple claims of NTP's patents. The court awarded NTP significant damages and issued a permanent injunction against RIM, reflecting the jury's determination of willful infringement and the strength of NTP's patent claims.

NTP, Inc. prevailed in the case, as the jury found that RIM's BlackBerry system infringed on multiple claims of NTP's patents. The jury awarded damages to NTP in the amount of $53,704,322.69, reflecting the strength of NTP's patent claims and the willfulness of RIM's infringement.

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