Fed Circuit invalidates data patent, in win for Amazon
Amazon and games developer Blizzard Entertainment, a subsidiary of Activision Blizzard, have succeeded in invalidating a patent owned by Swiss company AC Technologies
The US Court of Appeals for the Federal Circuit issued the precedential decision on Wednesday, January 9.
The Federal Circuit heard the case after AC appealed against a judgment of the Patent Trial and Appeal Board (PTAB) to invalidate certain claims of its patent for a data management system.
Titled “Data access management system as well as a method for data access and data management for a computer system” (US number 7,904,680), the patent was invalidated on the ground of obviousness.
Amazon and Blizzard filed for an inter partes review (IPR) of the patent, which had been granted in 2011, citing a 1998 research paper by Michael Rabinovich of multinational conglomerate AT&T as prior art. According to the companies, Rabinovich’s article anticipated certain claims of the patent and rendered other claims obvious.
AC argued that the system outlined in Rabinovich’s paper required the storage of a complete data file, and that its patent, construed correctly, required “redundantly storing file pieces”.
The Federal Circuit rejected this argument, noting that no claim in the patent limits how many data pieces the system may copy and store, and that claim 1 of the patent requires the storage of a complete file.
Much of the dispute also focused around the PTAB’s decision to invalidate the remaining claims of the patent on grounds raised by Amazon and Blizzard, but not addressed in the final written decision. AC claimed the PTAB had “exceeded its authority and deprived it of fair process”, according to the Federal Circuit ruling.
The Federal Circuit affirmed the decision of the PTAB, ruling that if the board initiates an IPR, it must address all grounds of unpatentability raised by the petitioner. In response to AC’s argument that the PTAB had exceeded its statutory authority by reviewing the claims, the court said that it would have “violated the statutory scheme had the board not done so”.
Costs were awarded to Amazon and Blizzard.
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