Background
TrackTime, LLC sued Amazon.com Services LLC and related entities for infringement of two patents covering methods for navigating multimedia files on mobile devices using time-correlated transcripts. The district court held the asserted claims of the ‘978 patent invalid for indefiniteness after construing ‘executable program code’ limitations as means-plus-function terms lacking adequate structural disclosure. For the ‘638 patent, a jury found claim nine invalid for anticipation by a prior art reference called LiveNote and not infringed. The district court denied TrackTime’s post-trial motions for judgment as a matter of law and a new trial.
The court’s reasoning
Regarding the ‘978 patent, the court determined that the district court’s analysis was insufficient under the intervening precedent in Dyfan, LLC v. Target Corp. The court explained that the inquiry must focus on whether the claim terms, read in full context, recite sufficient structure to perform the claimed functions of annotation and synchronous play on a mobile device. Because the district court did not fully address whether the terms were generally known in the art as names for structure or whether the specification provided adequate detail, the court vacated the ruling and remanded for further proceedings. Regarding the ‘638 patent, the court affirmed the finding of anticipation. The court held that the LiveNote reference disclosed a tablet PC, which qualifies as a mobile computing device, and disclosed a touch-sensitive input interface operable with a pen or finger. The court found sufficient evidence supported the jury’s verdict and that the district court did not abuse its discretion in denying a new trial.
We agree to this extent: Further analysis of the issue is warranted in light of our intervening precedent.
Opinion at page 2
What it means going forward
The decision requires the district court to re-evaluate the claim construction of the ‘978 patent to determine if the ‘executable program code’ limitations invoke Section one hundred twelve, subsection f. The ruling confirms that the ‘638 patent claims are invalid due to anticipation, effectively ending infringement liability for that patent.