Enzo Biochem Inc. v. Applera Corp. No. 2014-1321, March 16, 2015 (precedential) (2-1);
U.S. Patent No. 5,449,767

Key point(s):

• Factual findings for claim construction by a district court based on expert testimony may not override an analysis based on the totality of the specification.

MobileMedia Ideas LLC v. Apple, Inc., Nos. 2014-1060 and 2014-1091, March 17, 2015 (precedential) (3-0); Patent Nos. 6,427,078, 6,070,068, 6,253,075, and RE 39,231

Key point(s):

• Corresponding structure for means-plus-function claim terms is only structures linked to the function in the specification.
• A low level of ordinary skill can impede a finding of motivation to combine.

In re Hitachi Metals, Ltd., No. 2014-1689, March 17, 2015 (nonprecedential) (3-0);
Patent No. 5,645,651

Key point(s):

• In determining whether a claim is invalid under obviousness-type double patenting, the specification can be used to understand whether what is claimed was merely modified in an obvious manner.

Smith & Nephew Inc. v. Arthrex, Inc., No. 2014-1691 and 2014-1694, March 18, 2015 (nonprecedential) (2-1); Patent No. 5,601,557

Key point(s):

• A final ruling will not be upset without a concrete showing of how a new ruling changes the resolution of the case.
• Acceptable substitutes for a lost profits inquiry are determined by asking what a buyer would purchase if the infringing product was not sold.

Flexiteek Americas Inc. v. Plasteak, Inc., No. 2014-1214, March 19, 2015 (nonprecedential) (3-0); Patent No. 6,895,881

Key point(s):

• A technology tutorial that includes physical products of the parties is not per se improper.
• A claim construction can read in limitations from the specification that are necessary to achieve claimed objectives.

Two-Way Media LLC v. AT&T, Inc., No. 2014-1302, March 19, 2015 (precedential) (2-1);
Patent Nos. 5,778,187 and 5,983,005

Key point(s):

• Incorrectly labeled notices of electronic filings do not excuse a party who does not read the underlying order.

Senju Pharmaceutical Co., Ltd. v. Lupin Limited, No. 2013-1630, March 20, 2015 (precedential) (2-1); Reexamined Patent No. 6,333,045

Key point(s):

• A limitation will not be read into a claim from another claim or from a stated purpose in the specification for an obvious analysis.

Oracle America, Inc. v. Google, Inc., No. 2014-1351, March 20, 2015 (non-precedential) (3-0);
Patent No. 6,910,205

Key point(s):

• Claim construction should be the broadest reasonable interpretation in view of the plain meaning of the claims and the specification.

LSI Corporation v. United States International Trade Commission, No. 2014-1410, March 20, 2015 (non-precedential) (3-0); Patent Nos. 6,452,958 and 6,707,867

Key point(s):

• For relief under 19 U.S.C. § 1337, the ITC must find that an industry related to products that are covered by a patent exists or is being established through substantial investment.