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Skyhook Wireless, Inc. v. Google, Inc.

Citations: 159 F. Supp. 3d 144; 2015 U.S. Dist. LEXIS 86935; 2015 WL 10012985Docket: CIVIL ACTION NO. 10-11571-RWZ

Court: District Court, D. Massachusetts; February 17, 2015; Federal District Court

Narrative Opinion Summary

In a patent infringement case, Skyhook Wireless, Inc. accused Google, Inc. of infringing several patents related to wireless location services. Google sought summary judgment on the grounds of indefiniteness and non-infringement for various patents, including U.S. Patent Nos. 8,154,454, 8,223,074, and 8,242,960. The litigation involved multiple rounds of complaints and consolidations, with significant claims of indefiniteness and non-infringement addressed by the court. The court denied Google's motion for summary judgment on indefiniteness, affirming that the claims provided reasonable certainty about the invention's scope. Additionally, the court found issues of material fact regarding Google's alleged non-infringement, particularly concerning the interpretation of terms like 'reference database' and the application of the doctrine of equivalents. Skyhook presented evidence and expert testimony supporting claims of both direct and indirect infringement, including Google's promotion of infringing functionalities in its systems. The court's rulings allowed the case to proceed to trial on several contested issues, emphasizing the need for a jury to resolve factual disputes regarding Google's alleged infringement activities.

Legal Issues Addressed

Doctrine of Equivalents in Patent Infringement

Application: Skyhook argued that Google's practices could infringe under the doctrine of equivalents, which was supported by expert testimony and denied Google's motion for summary judgment.

Reasoning: Skyhook’s expert, Mr. Geier, provides sufficient opinions on this theory in his report.

Indirect Patent Infringement

Application: Skyhook alleged Google's indirect infringement by providing necessary components and promoting their use, supported by expert testimony and documentary evidence.

Reasoning: Skyhook argues against Google’s claim that it lacks evidence for inducement regarding the ’219 patent, presenting expert testimony from Mr. James Geier.

Patent Claim Construction

Application: The court considered the interpretation of claim language, especially terms like 'reference database' and 'location,' in determining infringement.

Reasoning: The subjective nature of terms like 'reference database' necessitates careful legal interpretation based on the language of the claims and supporting evidence.

Patent Invalidity Due to Indefiniteness

Application: The court examined Google's motion for summary judgment, declaring the invalidity of certain patents based on the indefiniteness of the term 'inferring.'

Reasoning: Google's motion for summary judgment regarding the definiteness of the claims in the ’454, ’074, and ’960 patents has been denied.

Summary Judgment Standards in Patent Infringement

Application: The court applied legal standards for summary judgment, which require the moving party to demonstrate the absence of genuine disputes over material facts, while the nonmovant must present specific facts to counter the motion.

Reasoning: The court grants such motions if no genuine dispute of material fact exists, requiring the moving party to prove this absence.