SameSurf, Inc. v. Intuit Inc.

SameSurf, Inc. v. Intuit Inc. The Federal Circuit affirmed the Board's construction of 'web browsing interaction data' as 'data related to web browsing interactions'—broad enough to encompass partially filled webpages—and therefore affirmed the Board's finding that all claims of the '145 patent are unpatentable for obviousness. Reinforces that absent lexicography or clear disclaimer, broad claim terms receive their full plain-and-ordinary-meaning scope, and a patentee cannot narrow a term post hoc by pointing to a single embodiment in the specification. Affirmed The '145 patent claims a method for a guest device to join a synchronized browsing session; the key disputed term was 'web browsing interaction data,' which Samesurf argued was limited to data describing host-device interactions, excluding partially filled webpages. The Board construed the term broadly as 'data related to web browsing interactions,' encompassing partially filled webpages, which led directly to the conclusion that prior art reference Lebrun disclosed the limitation. The Federal Circuit reviewed claim construction de novo and found no lexicography, disclaimer, or claim language requiring the narrower construction Samesurf urged; the specification's reference to a single embodiment was expressly labeled exemplary. The court rejected Samesurf's 'inoperability' argument, noting the claims require only that an application operate 'based on' the web browsing interaction data to access a website server, and Samesurf offered no evidence that partially filled webpages could not satisfy that requirement. This is a nonprecedential disposition and should be cited accordingly. claim construction § 103 remand non-precedential claim construction § 103 non-precedential claim construction § 103 non-precedential