Interdigital Technology Corporation & Ors v Lenovo Group Ltd & Ors [2023] EWCA Civ 105 (09 February 2023)

Interdigital Technology Corporation & Ors v Lenovo Group Ltd & Ors [2023] EWCA Civ 105 (09 February 2023)

The correct construction of the claims requires selecting the next smaller E-TFC and using its size as a multiplexing limit, not merely achieving the result that the data fits within that E-TFC. Filiatrault does not disclose this method, so the claims are novel. The judge erred in finding anticipation based on DXX/14, as the prior art did not disclose the required selection and use of the E-TFC as a limit.

Citation
[2023] EWCA Civ 105
Parties
Claimant/appellant: InterDigital Technology Corporation; Claimant/appellant: InterDigital Patents Holdings, Inc; Claimant/appellant: InterDigital, Inc; Claimant/appellant: InterDigital Holdings, Inc; Defendant/respondent: Lenovo Group Limited; Defendant/respondent: Lenovo (United States) Inc; Defendant/respondent: Lenovo Technology (United Kingdom) Limited; Defendant/respondent: Motorola Mobility LLC; Defendant/respondent: Motorola Mobility UK Limited
Jurisdiction
England and Wales
Judgment Date
09 February 2023
Procedural Posture
Patent Appeal / Court of Appeal Judgment on Appeal From High Court
Outcome
Appeal allowed
Legal Topics
Patent Validity, Claim Construction, Novelty, Standard Essential Patents, FRAND Licensing
Intellectual Property Patents Patent Validity Claim Construction Novelty Standard Essential Patents FRAND Licensing

Case Brief

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Parties

InterDigital Technology Corporation

Claimant/appellant

InterDigital Patents Holdings, Inc

Claimant/appellant

InterDigital, Inc

Claimant/appellant

InterDigital Holdings, Inc

Claimant/appellant

Lenovo Group Limited

Defendant/respondent

Lenovo (United States) Inc

Defendant/respondent

Lenovo Technology (United Kingdom) Limited

Defendant/respondent

Motorola Mobility LLC

Defendant/respondent

Motorola Mobility UK Limited

Defendant/respondent

Procedural Posture

Patent Appeal / Court of Appeal Judgment on Appeal From High Court

Legal Issues

  1. 1 Whether the patent claims are novel over the prior art (Filiatrault)
  2. 2 Proper construction of claim 1 and 5 of the patent
  3. 3 Whether the patent is essential and infringed under the standard

Ratio Decidendi

The correct construction of the claims requires selecting the next smaller E-TFC and using its size as a multiplexing limit, not merely achieving the result that the data fits within that E-TFC. Filiatrault does not disclose this method, so the claims are novel. The judge erred in finding anticipation based on DXX/14, as the prior art did not disclose the required selection and use of the E-TFC as a limit.

Court Disposition

Appeal allowed

Orders

  • Order of revocation of the patent set aside
  • Patent held valid and novel over Filiatrault