October 11, 2024

Federal Circuit Summary for Week Ending October 11, 2024

AlexSam, Inc. v. Aetna, Inc., No. 2022-2036 (October 8, 2024) (precedential) (3:0); Patent No. 6,000,608

Key point:

  • If the scope of claims is broader than the scope of a license, then not every act that might infringe the asserted claims “will necessarily be licensed.”

Applications In Internet Time, LLC v. Salesforce, Inc., No. 2024-1685 (October 10, 2024) (nonprecedential); Patent Nos. 7,356,482, and 8,484,111

Key point(s):

  • When a limitation sought to be read into an independent claim is recited in a dependent claim, the doctrine of claim differentiation is at its strongest.
  • A grant of summary judgment of obviousness based on erroneous claim constructions would be vacated.

Related Team:

Malgorzata (Gosia) A. Kulczycka, Ph.D., J.D.

Partner