In Win For Google, CAFC Holds Patentees May Not Bend Claim Terms to Fit Their Needs
On August 26, the U.S. Court of Appeals for the Federal Circuit (CAFC) affirmed the decision of the United States District Court for the District of Delaware, holding Google LLC did not infringe patents held by Data Engine Technologies LLC (DET). DET sued Google for infringing certain claims of U.S. Patent Nos. 5,590,259; 5,784,545; and 6,282,551 (the Tab Patents). The Tab Patents are directed to systems and methods for displaying and navigating three-dimensional electronic spreadsheets by use of user customizable “notebook tabs” on a spreadsheet interface. The prior art discussed in this trio of patents explained that “three-dimensionality, as presently implemented, is an advanced feature beyond the grasp of many spreadsheet users.” ‘259 patent col. 3 ll. 9-11. Accordingly, the Tab Patents explain, prior art spreadsheets require the user to manipulate each individual spreadsheet within a three-dimensional spreadsheet as an individual window in a graphical window environment. By contrast, the Tab Patents recite notebook tabs that allow the user to simply “flip through” several pages of the notebook to rapidly locate information.