Rovi Guides, Inc. v. Videotron Ltd.

Rovi Guides, Inc. v. Videotron Ltd.

Applying purposive claim construction for a skilled person defined as a team of electrical engineers and computer scientists with a few years’ industry experience, the Court found the asserted claims were either anticipated or rendered obvious in light of the cited prior art (notably Blake, DAVIC and Florin) and the common general knowledge; accordingly all asserted claims were invalid and Rovi’s action was dismissed while Videotron’s counterclaim was allowed. Where claims survived validity they were not infringed because key claim elements were not present in Videotron’s illico 2 architecture (notably the Local IPG being configured to record).

Citation
2022 FC 874
Parties
Plaintiff/defendant by Counterclaim: Rovi Guides, Inc.; Defendant/plaintiff by Counterclaim: Videotron Ltd.
Court
Federal Court
Jurisdiction
Canada
Judgment Date
23 June 2022
Procedural Posture
Patent Infringement and Validity Counterclaim / Final Judgment After Trial
Outcome
Plaintiff's action dismissed; Defendant's counterclaim granted; asserted patent claims declared invalid and certain claims found not infringed
Legal Topics
Infringement, Invalidity, Anticipation, Obviousness, Claim Construction, Remedies, Accounting of Profits, Reasonable Royalty
Source Language
English
Intellectual Property Patent Law Technology Law Infringement Invalidity Anticipation Obviousness Claim Construction +3 more

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Parties

Rovi Guides, Inc.

Plaintiff/defendant by Counterclaim

Videotron Ltd.

Defendant/plaintiff by Counterclaim

Procedural Posture

Patent Infringement and Validity Counterclaim / Final Judgment After Trial

Legal Issues

  1. 1 Claims construction of asserted patent claims
  2. 2 Priority/claim date determination
  3. 3 Infringement (direct and induced)

Ratio Decidendi

Applying purposive claim construction for a skilled person defined as a team of electrical engineers and computer scientists with a few years’ industry experience, the Court found the asserted claims were either anticipated or rendered obvious in light of the cited prior art (notably Blake, DAVIC and Florin) and the common general knowledge; accordingly all asserted claims were invalid and Rovi’s action was dismissed while Videotron’s counterclaim was allowed. Where claims survived validity they were not infringed because key claim elements were not present in Videotron’s illico 2 architecture (notably the Local IPG being configured to record).

Court Disposition

Plaintiff's action dismissed; Defendant's counterclaim granted; asserted patent claims declared invalid and certain claims found not infringed

Orders

  • The Plaintiff's action is dismissed.
  • The Defendant's counterclaim is allowed.