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Verint Systems Inc. v. Red Box Recorders Ltd.

Citations: 166 F. Supp. 3d 364; 2016 WL 54688; 2016 U.S. Dist. LEXIS 612Docket: 14-cv-5403(SAS)

Court: District Court, S.D. New York; January 3, 2016; Federal District Court

Narrative Opinion Summary

In this case, Verint Systems Inc. and Verint Americas Inc. accused Red Box Recorders LTD. of infringing on seven patents related to technologies for recording, monitoring, analyzing, and securing electronic communications. The dispute centered on the interpretation of twelve claim terms, with Verint seeking a declaration of infringement and Red Box countering with claims of non-infringement and invalidity. A Markman hearing was held to address these disputed terms, with Red Box challenging many as indefinite means-plus-function claims under 35 U.S.C. § 112, para. 6. The court found several claims invalid due to indefiniteness, lacking adequate structural disclosure for the functions described. The court also addressed the use of terms of degree, such as 'substantial' and 'substantially,' concluding these provided enough functional scope and were not indefinite. The case highlights the complexities of patent law, particularly concerning claim construction and the requirements for adequately defining claim terms in patent specifications. Ultimately, a number of claims were invalidated, and a conference was scheduled to further address the case's proceedings.

Legal Issues Addressed

Claim Construction and Markman Hearing

Application: A Markman Hearing was conducted to address the disputed terms, focusing on the interpretation of twelve claim terms from the patents in question.

Reasoning: A Markman Hearing was conducted on November 11, 2015, to address the disputed terms.

Indefiniteness of Patent Claims

Application: The court found specific claims invalid for indefiniteness due to a lack of structural details or ambiguous terms.

Reasoning: Specific claims from Patent Nos. 7,203,285, 8,189,763, 7,774,854, RE43,324, and RE43,386 have been found invalid for indefiniteness.

Means-Plus-Function Claim under 35 U.S.C. § 112, para. 6

Application: Red Box argued that several claim terms are means-plus-function claims lacking structural disclosure, rendering them indefinite.

Reasoning: Red Box contests their validity, arguing they are indefinite, particularly criticizing eleven terms as means-plus-function claims lacking adequate structural disclosure.

Patent Infringement under U.S. Patent Law

Application: Verint claimed that Red Box infringed on seven patents related to electronic communications technologies, seeking a declaration of infringement.

Reasoning: Verint seeks a declaration of infringement under U.S. law, while Red Box counters with claims for non-infringement and invalidity of the patents.

Use of Terms of Degree in Patent Claims

Application: The court evaluated terms like 'substantial' and 'substantially' for definiteness, concluding they are not indefinite as they provide functional scope.

Reasoning: The Court determined that the terms in question are not indefinite and do not require construction.