Indacon, Inc. v. Facebook, Inc. (Fed. Cir. June 6, 2016) (Before Reyna, Newman, and Stoll, J.) (Opinion for the court, Stoll, J.) Click Here for a copy of the opinion.
Indacon is the owner of the ‘276 patent, which is a method and system for searching and manipulating files in a database, particularly through the insertion of automatically generated hyperlinks. Indacon sued Facebook, alleging that its software infringed certain claims. After claim construction, the parties stipulated to non-infringement, and the court entered judgment in Facebook’s favor. Indacon appealed, disputing the construction of several terms.
The Court held that the specification was the best guide to the meaning of a disputed term. The Court also noted that the prosecution history is part of the intrinsic evidence and can inform the meaning of the claim language. One of the disputed terms, “alias,” was construed as a “textual expression that the user can define to serve as an alternative name or label”. Indacon disputes whether this term encompasses graphical expression as well as text and whether an alias is a hyperlink. The Federal Circuit agreed with the district court that “alias” in the patent was limited to textual expression. Indacon disputed the construction of “alias” because it was erroneously based on its use in conjunction with the word “term.” Indacon did not dispute the construction of “term”, but argued that “alias” was not dependent on the meaning of “term”. The Court agreed with the district court’s approach regarding the term alias. The Court disagreed and noted that nothing in the specification suggested that “alias” encompassed graphical expression. Instead, it described an “alias” as a “term”, which is limited to textual expression. The prosecution history additionally failed to support an interpretation encompassing graphical expression.
The district court construed “custom link” as a “link the user can define using a chosen term that allows each instance of the term in the plurality of files to be identified and displayed as a link to a file chosen by a user, without modifying the original database files.” Indacon objected to this construction, as well as the construction of “custom linking relationship” and “link term” because they all excluded creation of a link for less than all instances of a defined term. The Court disagreed and adopted the district court’s constructions as limited to allowing each instance of a “link term” to be identified and displayed. The Court agreed with Facebook in that these claim terms had no accepted meaning in the art, which meant that they cannot be construed broader than the specification disclosuses. The Court noted that the prosecution history also provided support for the district court’s construction. Further, because the other evidence was persuasive, there was no need to determine whether certain statements made by the patentees during prosecution rose to clear and unmistakable disclaimer, which is what Facebook argued in the alternative.
Indacon’s claim differentiation arguments also failed to persuade, because all of the other claims were independent claims that were not identical in scope; not dependent claims with clarifying limitations. Thus, the district court’s claim construction was affirmed, as was the judgment of noninfringement.
Parker Hancock and Puja Dave also contributed to this case summary.