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4 June 2021PatentsAlex Baldwin

Amazon didn’t infringe digital filing IP, Fed Circuit rules

Online retailers including Amazon and BestBuy have survived a patent infringement lawsuit after the US Court of Appeals for the Federal Circuit cleared them of infringing digital filing IP.

The precedential opinion handed down yesterday, June 3 saw the court affirm a previous district court ruling, which found that the 18 defendants and cross-appellants had not infringed the patents owned by tech company SpeedTrack.

The decision hinged on claim construction, relating to the definitions of hierarchical relationship in digital filing systems. The Federal Circuit approved the district court’s construction, favouring the defendants.

The Speedtrack patent (US number 5,544,360) was assigned in 1999 and covers a “computer filing system for accessing files and data according to user-designated criteria”.

SpeedTrack’s invention uses “hybrid” folders, which contain files whose content overlaps with more than one physical directory.

It does this by creating category descriptions that have no “predefined hierarchical relationship,” which SpeedTrack defines as an organisational method “analogous to paper filing systems”. This can become “very cumbersome” when dealing with a large number of files or ill-defined categories, SpeedTrack claimed.

In its original 2009 complaint, SpeedTrack alleged that the search functions on the retailers’ websites used categorisation systems that included no predefined hierarchical relationship, similar to its own invention. The case was put on hold until SpeedTrack’s litigation with Walmart over infringement of the ‘360 patent concluded in 2012.

In 2019, the US District Court for the Northern District of California issued a claim construction order to clarify the wording “no predefined hierarchical relationship” and in March 2020 issued a final judgment claiming that none of the retailers infringed on SpeedTracks patent.

Federal Circuit judge Sharon Prost wrote in yesterday’s judgment: “It is undisputed that cross-appellants do not infringe under the district court’s clarified construction. Therefore, we need only decide whether that construction is correct. We conclude that it is.”

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