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Federal Circuit Affirms Claim Construction and Judgment of Noninfringement in Vasudevan Software, Inc. v. MicroStrategy, Inc.

Strategic Insights

— 1 min read

The Federal Circuit has handed down a significant decision in Vasudevan Software, Inc. v. MicroStrategy, Inc., affirming the district court's claim construction and judgment of noninfringement. The dispute centered on the interpretation of the term "disparate databases" in four patents owned by Vasudevan Software, Inc. The court's decision provides valuable insights into the importance of considering the prosecution history and the nuances of claim construction in patent litigation.

Key Takeaways:

  • The Federal Circuit affirmed the district court's construction of the claim term "disparate databases," holding that it requires the absence of all compatible keys, record IDs of similar value, and record IDs of similar format in the schemas or structures.
  • The court found that the prosecution history controls the interpretation of the term, and that the applicant's statements during prosecution define the meaning of the claim term.
  • The court also held that the claim term "incompatible databases" is synonymous with "disparate databases," as the applicant consistently argued that the two terms are equivalent.
  • The court reversed the district court's grant of SJ of invalidity based on lack of written description, finding that there was a genuine issue of material fact regarding whether the patents-in-suit disclose how to access disparate databases.
  • The court also reversed the district court's grant of SJ of invalidity based on lack of enablement, finding that there was a genuine issue of material fact regarding whether the '006 patent specification provides a reasonable amount of guidance with respect to the direction in which experimentation should proceed.

Statistics:

  • The patents-in-suit are U.S. Patent Nos. 6,877,006, 7,167,864, 7,720,861, and 8,082,268.
  • The dispute centered on the interpretation of the claim term "disparate databases" in the patents-in-suit.
  • The court considered the prosecution history, the specification, and extrinsic evidence in its decision.
  • The court found that there were genuine issues of material fact regarding whether the patents-in-suit disclose how to access disparate databases and whether the '006 patent specification provides a reasonable amount of guidance with respect to the direction in which experimentation should proceed.

Sources:

  • In Vasudevan Software, Inc. v. MicroStrategy, Inc., Nos. 14-1094, -1096 (Fed. Cir. Apr. 3, 2015).
  • [Fed. Circuit opinion](http://www.cafc.uscourts.gov/sites/default/files/2015-1094.opinion.4-3-2015.pdf).
  • [Last Month at the Federal Circuit, May, 2015](http://www.finnegan.com/Last-Month-at-the-Federal-Circuit-May-2015).

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