CAFC vacates decision of ED Va in Virginia Innovation v. Samsung
Innovations a victor.
Plaintiff and appellant Virginia Information Sciences,
Inc. (VIS) appeals from stipulated final judgments of noninfringement
and invalidity entered in favor of Samsung
Electronics, Co., Ltd., Samsung Electronics America, Inc.,
and Samsung Telecommunications America LLC (collectively,
Samsung) by the United States District Court for
the Eastern District of Virginia in two consolidated patent
infringement actions. Because (1) the intrinsic evidence
before us does not support the district court’s construction
of a claim term central to the parties’ dispute, (2) the
specification of the patents-in-suit suggests that the term
has an established understanding in the art, and (3) the
parties have not sufficiently developed the record with
regard to that established understanding, we vacate and
remand for further proceedings.
Result: ED Va decision--VACATED AND REMANDED
court adopted Samsung’s reasoning, narrowing its construction
of “display format” to exclude signals in formats
that required further deconstruction or reassembly at the
external monitor in order to be displayed by the monitor.
VIS SJ II, 2014 WL 1685932 at *10.
This was error. Nothing in the specification mentions—much
less prohibits—the “deconstruction” or
“reassembly” of video signals at the external display, key
components of the district court’s ultimate construction of
the term “display format.” Nor do the parties identify
anything in the prosecution history suggesting that the
meaning of “display format” is tied to the absence of any
“deconstruction,” “decoding,” “reassembly,” or other
processing of the converted video signal by the external
monitor. Indeed, these terms appear to have been introduced
by VIS when analogizing a pre-assembled nursery
crib to compressed video signals in its summary judgment
briefs. J.A. 2813, 4919–20.