“While Red Hat argued that the specification adopted an open-ended definition for computer-readable media, the Court of Appeals ruled that, in the context of the claim language directed to hardware storage, “computer-readable A possible recording medium is a temporary medium.”
On April 12, the United States Court of Appeals for the Federal Circuit (CAFC) ruled that Sequoia Technology, LLC v. Dell, Inc. Under 35 USC § 101, reverses part of the District of Delaware ruling invalidating claims of digital storage patents owned by Sequoia. Although the ruling restores Sequoia’s rights to the patent claims at issue in this case, the Federal Circuit upheld some of the district court’s claim construction orders. It upheld the finding that Dell and the other defendants did not infringe her Sequoia asserted patent claims.
Judge Stark vacates the computer-readable media claim. In re Nuijten
At issue in the appeal is US Patent No. 6,718,436. How to manage logical volumes to support dynamic online resizing and software raids, and to minimize metadata and the computer-readable media that store it.The invention claimed in the ‘436 patent addresses the traditional management of logical volumes or virtual disk drives built within a RAID (Redundant Array of Independent Disks) architecture for storing the same data on multiple disks. increase. Specifically, the claimed method addresses large size metadata files stored in RAID-formatted logical volumes that can cause slow system boot times.
Sequoia, the exclusive licensee of the ‘436 patent owned by the Electronics and Telecommunications Research Institute (ETRI), first filed lawsuits against other customers of computing company Dell and enterprise software developer Red Hat. . The product accused in this incident was a Red Hat software tool for resizing logical volumes in units smaller than entire disk partitions. Red Hat later filed a lawsuit seeking declaratory judgment of invalidity and non-infringement of the ‘436 patent.
After consolidating these actions, U.S. District Judge Leonard Stark invalidated claims 8 through 10 of the ‘436 patent based on its construction of the claim term “computer-readable medium.” accepted by the district court. Although the specification of the ‘436 patent did not include transitory media in its non-exhaustive list of computer-readable recording media, Judge Stark noted that in this case he was a Red Hat expert. Admitted the extrinsic evidence provided by the witness. Based on his 2007 ruling of the Federal Circuit, In re Nuijtenthe district court ruled invalid because transitory media, such as computer signals, are not directed to patentable subject matter under Section 101.
Context is the key to building
In denying the district court’s claim construction leading to invalidity of section 101, the Federal Circuit found that the claim language actually stated a narrow limitation of “a computer-readable recording medium containing instructions.” I paid attention to A person skilled in the art would not understand the use of such signals to store instructions in a memory system, since transient signals do not persist over time. Further support for this conclusion, the Federal Circuit determined, is the complete absence of any reference to ephemeral media in the ‘436 patent’s specification. While Red Hat argued that the specification adopted an open-ended definition for computer-readable media, the Court of Appeals ruled that, in the context of the claim language directed to hardware storage, “computer-readable media ‘ has clarified that it cannot contain temporary items. media.
While the district court relied in part on Red Hat’s expert testimony and extrinsic evidence from other U.S. patents, the Federal Circuit found the reliance to be inconsistent with the substantive evidence of the patent record itself. Citing the language of the Federal Circuit’s key judgment, the Court of Appeals found that Judge Stark contradicted the expert testimony provided by Red Hat with “the construction of the claims mandated by the patent’s written record.” Therefore, it was recognized that it should have been discounted. Phillips v. AWH Corporation (2005).
Further, the Federal Circuit discounted the definition of “computer-readable medium” from 34 contemporaneous patents and patent applications, noting that these documents do not establish the plain and ordinary meaning of that claim term. I pointed out that Finally, in February 2010, the Federal Circuit dismissed Red Hat’s construction dispute over a memorandum by then-Director of the United States Patent and Trademark Office (USPTO), David Kappos, regarding subject matter eligibility for computer-readable media. Dismissed, the memo should amend the computer-readable media claim with “non-transitory” language to overcome the Section 101 problem.
Red Hat and enterprise software customers still avoid infringement claims
Sequoia, represented by former USPTO Director and Irell & Manella partner Andrei Iancu, also found on appeal that the district court misconstrued the claim terms “disk partition” and “logical volume,” both of which granted noninfringement. claimed to support The Federal Circuit noted numerous instances of the ‘436 patent’s claim language in which entire disk partitions, rather than parts or “extents,” form the claimed logical volume. The patent specification also states that the use of disk partitions to form logical volumes achieves the goal of minimizing the size of metadata files. The specification also states that a disk partition is the “minimum unit” of a logical volume, and the Federal Circuit acknowledged that the patent claims should not be limited based on the preferred embodiments in the specification. However, the Court of Appeals concluded that this embodiment is supported by the language of the plain argument.
The Federal Circuit also found that patentee ETRI’s representations to the USPTO regarding the ‘436 patent further clarified that a disk partition is the smallest building block of a claimed logical volume. bottom. ETRI may use prior art references claimed by Red Hat to between the parties Please review the (IPR) petition, noting that these references use extents or subsets of disk drives to form logical volumes. Sequoia argued that ETRI merely pointed out the lack of disk partitions in the prior art references, but the Federal Circuit found that ETRI’s statement in the IPR regarding logical volumes in the ‘436 patent identified that it apparently involves adding or removing extents “at the level of disk partitions”. Eliminated constructs that allow extents themselves to form logical volumes.
Sequoia also advanced its interpretation of Claim 1’s limitations, which refer to “an extent allocation table for indicating whether each extent in a disk is used or not.” The patent holder argued that “used or unused” indicated that some extents in the allocation table were not used to build the logical volume. While the claim language did not support Sequoia’s or Red Hat’s proposed construction, the Federal Circuit held that the preferred embodiment disclosed by the specification of the ‘436 patent “used extents from the allocation table for storage.” logical volume. The Federal Circuit also ruled that a paper on volume management in a storage area network (SAN) environment written by the inventor of the ‘436 patent and cited by the patent found that extents were “used” when storing data. We also found that we further proved that Although the invention claimed by the ‘436 patent differed from the system disclosed in the paper on the SAN environment, this definition, as supported by the patent’s specification, is “used or used.” is consistent with the Federal Circuit’s interpretation that
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