Federal Circuit, in Apple Inc. v. Samsung Electronics Co., Ltd. et. al., Held That Apple's Analyzer Server Patent Not Infringed by Samsung, And Apple's Slide-to-Unlock And Autocorrect Patents are Invalid for Obviousness
Apple Inc. sued Samsung Electronics Co., Ltd. for infringement of five U.S. patents, including U.S. Patent Nos. 5,946,647 (the Analyzer Server patent), 8,046,721 (the Slide-to-Unlock patent), and 8,074,172 (the Autocorrect patent). The district court entered a judgment of $119.6 million for Apple for infringement of these three patents by Samsung. The district court denied Samsung’s motion for judgment as a matter of law (JMOL). In a decision on February 26, 2016, the Federal Circuit reversed, holding that Samsung did not infringe the Analyzer Server patent and that the Slide-to-Unlock and Autocorrect patents are invalid for obviousness.
The Analyzer Server patent is directed to software to detect structures such as phone numbers in text, turning those into links, which allows a user to click on the structure to take an action, such as making a phone call. The independent claim requires “an analyzer server for detecting structures in the data, and for linking actions to the detected structures.” The district court adopted the Federal Circuit’s previous construction of the term “analyzer server” to require that the analyzer server is separate from a client that receives data (Apple Inc. v. Motorola, Inc., 757 F.3d 1286, 1304 (Fed. Cir. 2014). Apple argued that the software code stored in shared program libraries in Samsung’s Browser and Messenger applications were the “analyzer server.” Experts for both parties, however, testified that the shared library code is “used” by the Messenger and Browser applications, and not run separately. As such, the Federal Circuit held that no reasonable jury could have concluded that the accused device met the “analyzer server” requirement, and reversed the district court’s denial of Samsung’s motion for JMOL on non-infringement.
The Slide-to-Unlock patent is directed to the iPhone’s “slide to unlock” feature, where a user can slide a moving image across the screen of the phone with his finger to unlock the phone. The parties do not dispute that two references, Plaisant in view of Neonode, disclose all of the claimed features of the Slide-to-Unlock patent. Unpersuaded by Apple’s arguments, the Federal Circuit held that Plaisant and Neonode are analogous art, and that the strong prima facie case of obviousness was not negated by Apple’s weak secondary consideration evidence. The Federal Circuit also rejected Apple’s argument that Plaisant taught away from the claimed invention because the claimed feature disclosed in Plaisant is not preferred (“the ‘mere disclosure of more than one alternative’ does not amount to teaching away from one of the alternatives where the reference does not ‘criticize, discredit, or otherwise discourage the’ solution presented by the disclosure.”) The Federal Circuit held the Slide-to-Unlock patent obvious in view of Plaisant and Neonode.
The Autocorrect patent covers “autocorrect” software on the phone that automatically corrects typing errors. The Federal Circuit noted that autocorrection features were known in the prior art, and that the combination of two prior art references, Robinson and Xrgomics, results in Apple’s Autocorrect invention. The Federal Circuit stated that the specification defines the field broadly as the general field of text input on portable electronic devices, and that Robinson and Xrgomics are within this general field. The Federal Court similarly found Apple’s secondary consideration arguments “very weak,” and not sufficient to overcome the strong prima facie case of obviousness. The Federal Circuit held the Autocorrect patent obvious in view of Robinson and Xrgomics.