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Judge Farnan: Claim construction in Leader v. Facebook

By Karen E. Keller, Andrew A. Lundgren et al.

In Leader Technologies, Inc. v. Facebook, Inc., C.A. No. 08-862-JJF (D. Del. Mar. 9, 2010), Judge Farnan recently construed claim terms related to a patent involving ?the ?management and storage of electronic information,? and specifically relat[ing] to ?new structures and methods for creating relationships between users, applications, files and folders.??

Plaintiff asked Judge Farnan to construe five claim terms, whereas defendant put forth three claim terms (down from its initial 31 claim terms, narrowed after the Markman hearing).

The construction of the eight disputed terms are as follows:

Context
?environment?

Judge Farnan found that this construction, proposed by plaintiff, was supported by the specification, and rejected defendants claim differentiation argument stating that ?the specification should prevail over claim differentiation principles.? Id. at 10.

Component
?a computer-related entity, either hardware, a combination of hardware and software, software, or software in execution.?

Judge Farnan rejected defendant?s argument that means-plus-function treatment was appropriate thereby construing the term as expressly defined in the specification. Id. at 14.

Ordering
?organizing?

Judge Farnan rejected defendant?s proposed construction because it read in a limitation not supported by the claim or the specification. Id. at 15.

Traversing
?navigation according to a specific path or route?

Many-to-many Functionality
?two or more users able to access two or more data files?

Judge Farnan rejected defendant?s argument that the claim term was indefinite. Id. at 22-24.

Dynamically
?automatically and in response to the preceding event?

Judge Farnan rejected plaintiff?s argument that the claim term required no construction because it is commonly used in the field, ?and one of ordinary skill in the art understands its meaning.? Id. at 24.

Metadata
Term given its plain and ordinary meaning

Judge Farnan determined that defendant?s proposed construction ?import[ed] unnecessary and unwarranted limitations? into the claim term. Id. at 27. Furthermore, the proposed construction was not supported by the prosecution history. Id. at 28.

Accesses [the data]
Term given its plain and ordinary meaning

Leader Technologies, Inc. v. Facebook, Inc., C.A. No. 08-862-JJF (D. Del. Mar. 9, 2010)

Full post as published by Delaware IP Law Blog on March 11, 2010 (boomark / email).