Adaptive Spectrum and Signal Alignment Inc v British Telecommunications Plc

Adaptive Spectrum and Signal Alignment Inc v British Telecommunications Plc

The Court held that BT's NGA system infringed claim 1 of ASSIA's 790 patent because the cap level table constitutes a PSTM indicating a plurality of possible transitions with priority values, and the system uses estimated data and sub-rules as required by the claim. The Court also held that claim 6 of the 495 patent is valid and infringed, as the system determines margin-related parameter values to meet performance targets, and the claim does not exclude selection from a lookup table. The Court rejected BT's procedural objection, finding the infringement case was properly pleaded by reference to the product and process description.

Parties
Appellant/respondent: Adaptive Spectrum and Signal Alignment Inc.; Respondent/appellant: British Telecommunications PLC
Jurisdiction
England and Wales
Judgment Date
11 November 2014
Procedural Posture
Civil Appeal (patents) / Appeal From High Court (patents Court)
Outcome
BT's appeal dismissed; ASSIA's cross-appeal allowed in part.
Legal Topics
Patent Infringement, Patent Validity, Claim Construction, Procedural Fairness
Intellectual Property Patents Patent Infringement Patent Validity Claim Construction Procedural Fairness

Case Brief

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Parties

Adaptive Spectrum and Signal Alignment Inc.

Appellant/respondent

British Telecommunications PLC

Respondent/appellant

Procedural Posture

Civil Appeal (patents) / Appeal From High Court (patents Court)

Legal Issues

  1. 1 Whether BT's NGA system infringes claim 1 of ASSIA's 790 patent
  2. 2 Proper construction of claim features in 790 and 495 patents
  3. 3 Whether claim 6 of 495 patent is valid and infringed

Ratio Decidendi

The Court held that BT's NGA system infringed claim 1 of ASSIA's 790 patent because the cap level table constitutes a PSTM indicating a plurality of possible transitions with priority values, and the system uses estimated data and sub-rules as required by the claim. The Court also held that claim 6 of the 495 patent is valid and infringed, as the system determines margin-related parameter values to meet performance targets, and the claim does not exclude selection from a lookup table. The Court rejected BT's procedural objection, finding the infringement case was properly pleaded by reference to the product and process description.

Court Disposition

BT's appeal dismissed; ASSIA's cross-appeal allowed in part.

Orders

  • BT's appeal on non-infringement of 790 dismissed.
  • ASSIA's appeal on 495 allowed; finding of infringement of claim 6 substituted.