MPH Technologies Oy v. Apple Inc.

MPH Technologies Oy v. Apple Inc. The Federal Circuit rejected the district court's construction limiting the '949 patent family's 'secure' terms to IPSec and 'unique identity' to IPSec-specific SPI values. It also reversed the indefiniteness ruling for the '581 patent because a skilled artisan would understand 'the secure connection' with reasonable certainty in light of the claim language and specification. Even repeated specification references to a preferred protocol may not justify importing that protocol into broad claim terms where the specification expressly says the invention is not restricted to that protocol. Reversed the indefiniteness determination, vacated the stipulated judgments of noninfringement and invalidity, and remanded. For the '949 patent family, the district court construed 'secure' as requiring IPSec and 'unique identity' as limited to SPI values, leading to a stipulated noninfringement judgment. The Federal Circuit held the intrinsic record did not clearly limit 'secure' to IPSec, emphasizing claim language, dependent claims, and specification statements that IPSec was preferred and that the invention was not restricted to existing protocols. Because the 'unique identity' construction rose and fell with the IPSec-based construction of 'secure,' the court rejected the SPI-only construction as well. For the '581 patent, the court held that 'the secure connection' in claim 1.e referred to the secure connection established between the mobile terminal and security gateway, as modified after the mobile terminal changed addresses. The court vacated the stipulated judgments and remanded for further proceedings. claim construction § 112(b) infringement remand non-precedential claim construction § 112(b) infringement remand non-precedential claim construction § 112(b) remand non-precedential