TrackTime, LLC v. Amazon.com Services LLC

TrackTime, LLC v. Amazon.com Services LLC The Federal Circuit vacated the indefiniteness ruling on the '978 patent because the district court did not adequately analyze, under intervening Dyfan precedent, whether the full “executable program code” limitations recited sufficient structure to avoid § 112(f). The court affirmed the judgment of invalidity of '638 patent claim 9 because substantial evidence supported the jury’s anticipation finding based on LiveNote. For software claims, Dyfan requires a claim-language-and-art-focused assessment of whether functional code terms connote structure, but trial verdicts on anticipation remain hard to disturb when supported by reference disclosures and credited expert testimony. Affirmed in part, vacated in part, and remanded. The '978 indefiniteness judgment was vacated and remanded for renewed § 112(f) analysis; the denial of JMOL and new trial as to the '638 patent was affirmed on the LiveNote anticipation ground. For the '978 patent, the disputed limitations recited mobile-device “executable program code” configured to facilitate annotation and synchronously play multimedia with a synchronization index. The Federal Circuit held the district court’s § 112(f) analysis was incomplete because it treated “executable program code” as generic without sufficiently addressing the limitations in full, the claimed functions, context, and relevant artisan understanding under Dyfan. On remand, the district court must assess whether the limitations, read in context, recite sufficient structure for annotation and synchronous play on a mobile computing device and integrable with the other claimed functionality; if § 112(f) applies, adequacy of corresponding structure remains to be addressed. For the '638 patent, the court affirmed anticipation by LiveNote, relying on evidence that LiveNote disclosed use on a tablet PC and a touch-sensitive interface, along with expert testimony the jury was entitled to credit. TrackTime forfeited its “data lookup” anticipation argument by not presenting it to the district court, and its new-trial challenge showed at most a conventional expert dispute. precedential claim construction § 112(f) § 112(b) § 102 remand waiver / forfeiture precedential claim construction § 112(f) § 112(b) § 102 remand waiver / forfeiture claim construction § 112(f) § 112(b) § 102 remand