The court held that the licensor of the patent-in-suit was improperly joined as a plaintiff, because the license transferred all significant rights in the patent and the rights that the licensee did retain (economic interests, limited termination rights, and an unfixed reversionary interest) were insufficient to show that it retained any exclusionary rights to the patent. Second, the court held that the District Court erred in holding that the patentee acted as her own lexicographer, thereby limiting the claim term “MAC address” to identifiers that are generated by a hub device, where the ordinary meaning of “MAC address” includes the universal assignment of identifiers in addition to assignment by a hub. The dissent believes that the patentee’s use of the term in the specification “Media Access (MAC) address” (not “Media Access Control (MAC) address,” which is the term defined in dictionaries) was significant and evidenced an intent to make clear that this term meant an address assigned by a hub device.
Azure Networks, LLC v. CSR PLC, Case No. 2013-1459 (November 6, 2014); Opinion By: Chen, joined by Reyna and Mayer, in part; Mayer, dissenting-in-part; Appealed From: Eastern District of Texas, Schneider, J. To read the court's opinion, click here.
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