Narrative Opinion Summary
This case involves an appeal by Cable Wireless Internet Services, Inc. (C.W.) from decisions of the U.S. District Court for the District of Massachusetts regarding the validity and infringement of certain claims of U.S. Patent No. 6,108,703, owned by Massachusetts Institute of Technology and licensed to Akamai Technologies, Inc. The patent pertains to a 'global hosting system' designed to reduce internet congestion. C.W. challenged the district court's denial of its motion for judgment as a matter of law and a permanent injunction regarding claims 1, 3, 5, and 9 of the patent. The Federal Circuit reversed the district court's decision on claims 1 and 3, finding them invalid due to anticipation by prior art under 35 U.S.C. § 102, and vacated the related portion of the injunction. However, it upheld the validity and infringement findings for claims 5 and 9, affirming the jury's verdict that they were neither anticipated nor obvious under 35 U.S.C. § 103(a). The case was remanded to adjust the scope of the permanent injunction. The decision was partially contested by Judge Newman, who dissented regarding the anticipation findings. Costs were not awarded.
Legal Issues Addressed
Anticipation under 35 U.S.C. § 102subscribe to see similar legal issues
Application: The court found claims 1 and 3 of the '703 patent invalid due to anticipation by prior art, specifically the '598 patent, which disclosed all limitations of these claims.
Reasoning: The Federal Circuit, led by Circuit Judge Gajarsa, reversed the district court's denial of C.W.'s motion concerning claims 1 and 3, finding these claims invalid due to anticipation by U.S. Patent No. 6,185,598 (the '598 patent) under 35 U.S.C. § 102.
Infringement Findings and Substantial Evidencesubscribe to see similar legal issues
Application: The court upheld the jury's findings of infringement for claim 9 based on substantial evidence, affirming the jury's verdict.
Reasoning: The jury found that dependent claim 9 of the '703 patent was infringed by C.W.'s Footprint 2.0 system, supported by substantial evidence from Dr. Bustavros's testimony.
Obviousness under 35 U.S.C. § 103(a)subscribe to see similar legal issues
Application: The court affirmed the jury's verdict regarding the nonobviousness of claims 5 and 9, as C.W. failed to demonstrate sufficient motivation to combine prior art references.
Reasoning: C.W. failed to demonstrate that no reasonable jury could find claims 5 and 9 nonobvious, as they could not identify sufficient motivation to combine the references cited.
Permanent Injunction and Scope Adjustmentsubscribe to see similar legal issues
Application: The court vacated part of the permanent injunction related to claims 1 and 3 and remanded the case for the district court to reassess the injunction's scope.
Reasoning: The court instructed the district court to modify the permanent injunction accordingly. However, the district court's denial of C.W.'s motion concerning claims 5 and 9 was affirmed, along with the continuation of the permanent injunction for those claims.