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Starhome GmbH v. AT&T Mobility LLC

Summarized by: 

Date Filed: 02-24-2014
Case #: 2012-1694
U.S. Court of Appeals, Federal Circuit
Full Text Opinion: http://www.cafc.uscourts.gov/images/stories/opinions-orders/12-1694.Opinion.2-20-2014.1.PDF
LexisNxis Link: 2014 U.S. App. LEXIS 3355
Westlaw Link: 2014 WL 685639

Patents: Claim Construction: Non-infringement was found when two figures were submitted in a claim and were ambiguous because they didn't rise to the level of clear intent to impart a novel meaning to the claim term.

Opinion (Schall): Starhome Gmbh (“Starhome”) sued AT&T Mobility, LLC and others for infringement of its ‘487 and ‘431 patents relating to improving the functionality of phone services for users in a roaming telephone network. At the center of the dispute was the term “intelligent gateway.” Starhome desired a broad interpretation of the term to include any network element that used databases and applied logic. Defendants wished for a narrow interpretation where “gateway” required the network element to transfer information to and from an external network. The district court construed the term narrowly because ”gateway” had a well-known technical meaning and because the inventors did not clearly redefine the term. Starhome then stipulated to the entry of judgment of non-infringement. Starhome only appealed the ‘487 patent and argued the specification did not require the gateway to be connected to an external network. Starhome relied on Figure 2 of the ‘487 patent, which showed the intelligent gateway connected solely to a single internal network. Defendants pointed to three dictionary definitions confirming that “gateway” refers to a point of interconnection between two or more networks and pointed out that Figure 2 was merely a simplified drawing of Figure 1, not a separate embodiment. The Court found that the specification explained Figure 2 as a simplified drawing of Figure 1 and that the use of “gateway” did not depart from its ordinary meaning as understood by one of ordinary skill in the art. Figure 2 inserted ambiguity at best, which did not rise to the necessary level of clear intent to impart a novel meaning to the claim term. Therefore, the Court fond no error in the district court’s construction and judgment of non-infringement was AFFIRMED.