Narrative Opinion Summary
The case involves an appeal by Hilgraeve Corporation against a district court decision that granted Symantec Corporation summary judgment of non-infringement for U.S. Patent No. 5,319,776, which pertains to computer virus detection software. Symantec also cross-appealed the ruling that it was not licensed to use the invention claimed in the '776 patent. The Federal Circuit vacated the summary judgment of non-infringement, identifying unresolved material facts about whether Symantec's products infringed the patent claims, specifically concerning the definition of 'storage.' The court affirmed that no license was established prior to March 2, 1999, based on Symantec's claims of acquiring rights through Delrina Corp. agreements. The court emphasized that patent infringement analysis involves claim construction and comparison with the accused device, requiring facts to be viewed favorably to the non-movant. The case was remanded for further proceedings, particularly to address factual disputes about the accused products' operations in relation to the '776 patent claims. No costs were awarded, and the court's decision maintained a strict interpretation of license agreement language under Ontario law, rejecting implied patent rights transfers.
Legal Issues Addressed
Construction of License Agreementssubscribe to see similar legal issues
Application: The court ruled that Symantec had not established a prior license for the '776 patent before March 2, 1999, as it failed to prove any rights were transferred from Delrina (Delaware) to Delrina (Canada) or Delrina Corp.
Reasoning: The district court ruled that Symantec had not established a prior license for the '776 patent before March 2, 1999, as it failed to prove any rights were transferred from Delrina (Delaware) to Delrina (Canada) or Delrina Corp.
Definition of 'Storage' Under Patent Lawsubscribe to see similar legal issues
Application: The court agreed with the McAfee II definition of 'storage' as occurring when incoming digital data is sufficiently present on a storage medium and accessible by the operating system, allowing viruses to spread.
Reasoning: The court agrees with the McAfee II definition of 'storage' and notes that Symantec claims it does not infringe based on this definition, while Hilgraeve asserts there are unresolved material facts regarding the accused devices' operations.
Patent Infringement Analysissubscribe to see similar legal issues
Application: The court emphasized that infringement can be established if a device is reasonably capable of satisfying claim limitations, regardless of potential non-infringing uses under unusual conditions.
Reasoning: The document emphasizes that infringement can be established if a device is reasonably capable of satisfying claim limitations, regardless of potential non-infringing uses under unusual conditions.
Summary Judgment of Non-Infringementsubscribe to see similar legal issues
Application: The Federal Circuit vacated the district court's summary judgment of non-infringement, determining that genuine questions of material fact remain concerning whether the features of the '776 patent claims are present in Symantec's accused products.
Reasoning: The Federal Circuit vacates the district court's summary judgment of non-infringement, determining that genuine questions of material fact remain concerning whether the features of the '776 patent claims are present in Symantec's accused products.