The court made the following rulings: (1) the jury’s verdict that the ‘078 (camera) patent claims were not proven to have been obvious was supported by substantial evidence that a person of ordinary skill in the art would not have been able to combine the two references as such combination would have been beyond his or her level of skill ; (2) the district court’s construction for a “means plus function” claim term was erroneous and, under the proper construction, Apple’s accused product did not infringe; (3) the court’s denial of Apple’s JMOL on the issue of obviousness of claim 24 of the ‘068 patent was erroneous, because Apple’s expert’s testimony that a claim feature was well within the common knowledge of those with skill in the art was unrebutted; (4) affirming the district court’s grant of JMOL to Apple that the ‘075 patent claims are obvious; and (5) vacating the district court’s grant of Apple’s motion for summary judgment of non-infringement on the ‘231 patent because the district court erred in construing the claim phrase “controlling the alert sound generator to change a volume of the generated alert sound.”

Mobilemedia Ideas LLC v. Apple, Inc., Case No. 2014-1060, -1091 (March 17, 2015); Opinion by: Chen, joined by Taranto and Bryson; Appealed From: District Court for the District of Delaware, Robinson, J. Read the full opinion here.

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