This appeal involved five patents asserted by Apple and two patents asserted by Samsung.
On Apple’s ’647 patent, which involved a system for recognizing structures in text (e.g., a phone number) and linking actions to the recognized text (calling the phone number). The claims at issue included the term “analyzer server.” The jury found infringement and the district court denied Samsung’s JMOL of non-infringement. The Federal Circuit, however, reversed, holding that Samsung’s devices do not meet the “analyzer server” limitation. In another case, the Federal Circuit construed “analyzer server” to require a routine that is separate from a client. The Samsung device, however, used program libraries, which were not separate from the software that performed the claimed functions, and therefore it did not meet this limitation.
On Apple’s ’721 patent, which involved the “slide to unlock” feature, the jury found the claims to be not obvious and the court denied Samsung’s motion for JMOL on obviousness. Two prior art references collectively showed each feature of the claims. Apple argued that the district court was correct, because one of the references teaches away from the claimed invention and there was no motivation to combine the references. The court rejected Apple’s arguments. Although the reference disclosed alternatives and it criticized the relevant disclosure, this is insufficient to find that the reference “teaches away.” The court also rejected Apple’s argument that there would not have been a motivation to combine, because one of the references was not relevant, analogous prior art. Analogous art is art of the same field of endeavor as the patent. Here, no reasonable jury could find that the reference was not in the same field of endeavor as the patent. The court lastly rejected Apple’s evidence of secondary considerations, including long felt need, industry praise, copying, and commercial success.
On Apple’s ’172 patent, which involved Apple’s “autocorrect” feature, the jury found the claims to be not obvious and the court denied Samsung’s motion for JMOL on obviousness. The Federal Circuit rejected Apple’s argument that the claims were not obvious because one of ordinary skill in the art would not have been motivated to make the combination. The court held that the references were in the same field as the claims and therefore a person of skill in the art would have been motivated to combine. The court further rejected Apple’s secondary considerations of non-obviousness arguments regarding copying and commercial success.
On Apple’s ’959 patent, which involved Apple’s “universal search” function, the court affirmed the jury’s verdict of non-infringement, because Samsung’s devices do not search the Internet, but rather blend data previously received.
On Apple’s ’414 patent, which involved Apple’s “background sync” functionality, the court affirmed the jury’s verdict of non-infringement, because the claims required three synchronization components, but Samsung’s devices had only two.
On Samsung’s ’239 patent, which involved remote video transmission, the court affirmed the construction of “means for transmission,” which requires software, and, pursuant to that construction, affirmed the judgment of non-infringement.
On Samsung’s ’449 patent, which involved compressing and organizing digital files, the court affirmed the jury’s verdict of infringement by Apple, as the jury’s verdict was reasonable in light of the evidence.
Apple Inc. v. Samsung Electronics Co., Ltd., Case Nos. 2015-1171, -1195, -1994 (February 26, 2016); Opinion by: Dyk, joined by Prost and Reyna; Appealed From: United States District Court for the Northern District of California, Koh, J. Read the full opinion here.