VLSI Technology LLC v. Intel Corporation

The United States Court of Appeals for the Federal Circuit reversed in part and affirmed in part a district court ruling in a patent infringement dispute. The appellate court held that a pretrial stipulation established a United States nexus for infringement and that prosecution history did not disclaim a claim limitation.

Background

VLSI Technology LLC sued Intel Corporation for infringement of eight patents, including United States Patent Number eight million five hundred sixty-six thousand eight hundred thirty-six. The district court granted Intel summary judgment of noninfringement based on extraterritoriality and rejection of the doctrine of equivalents, and struck the damages theories of VLSI’s expert Dr. Sullivan.

The court’s reasoning

The court reviewed the district court’s grant of summary judgment de novo. Regarding extraterritoriality, the court found the district court erred by ignoring a pretrial stipulation that deemed seventy percent of accused products to have a United States nexus. For the apparatus claims, the court held that the prosecution history did not contain clear and unmistakable disavowal of a broader interpretation of the claims. The court affirmed the striking of damages theories, finding the district court did not abuse its discretion under local patent rules due to insufficient disclosure.

What it means going forward

The ruling requires the district court to reconsider the infringement claims for the method and apparatus patents, allowing VLSI to proceed with its damages case using the remaining expert testimony.

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