Treehouse Avatar LLC v. Valve Corporation

CourtDistrict Court, W.D. Washington
DecidedNovember 25, 2019
Docket2:17-cv-01860
StatusUnknown

This text of Treehouse Avatar LLC v. Valve Corporation (Treehouse Avatar LLC v. Valve Corporation) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Treehouse Avatar LLC v. Valve Corporation, (W.D. Wash. 2019).

Opinion

1 HONORABLE RICHARD A. JONES 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 11 TREEHOUSE AVATAR LLC, CASE NO. C17-1860-RAJ 12 Plaintiff, 13 ORDER ON CLAIM v. CONSTRUCTION 14 VALVE CORPORATION, 15 16 Defendant. 17 18 This matter comes before the Court on the parties’ request for claim 19 construction. Dkt. # 139. 20 I. BACKGROUND 21 Plaintiff Treehouse Avatar LLC (“Plaintiff” or “Treehouse”) brings suit against 22 Defendant Valve Corporation (“Defendant” or “Valve”) for infringing its patent, 23 United States Patent No. 8,180,858 (“the ‘858 patent”). The ‘858 patent, issued on 24 May 15, 2012, relates to methods of collecting data from an information network in 25 response to user choices of a plurality of users navigating character-enabled (“CE”) 26 network sites on the network. Dkt. # 1-1. 27 1 Treehouse initially brought this patent infringement action against Defendant 2 Valve Corporation (“Defendant” or “Valve”) in Delaware in 2015. Dkt. # 15. In 3 December 2017, the case was transferred to this District. Dkt. # 116. 4 The parties initially filed their claim construction briefing in Delaware and 5 disputed thirty terms. See Dkt. ## 58, 63, 66, 69. After the case was transferred to this 6 Court, the parties requested, and were granted, leave to file a joint claim construction 7 briefing, consolidating the initial briefing and reducing the number of terms in dispute. 8 Dkt. # 128. The parties now ask the Court to construe ten disputed claim terms. Dkt. 9 # 139. 10 The court held a Markman hearing in this matter on November 8, 2019. Dkt. # 11 153. 12 II. LEGAL STANDARD 13 Claim construction is a matter of law. See Markman v. Westview Instruments, 14 Inc., 517 U.S. 370, 372 (1996). The specification of a patent begins with a written 15 description, which often includes drawings or illustrations, and “conclude[s] with one 16 or more claims particularly pointing out and distinctly claiming the subject matter 17 which the inventor . . . regards as the invention.” 35 U.S.C. § 112(b). The claims 18 reign supreme over the remainder of a patent; they alone “define the scope of patent 19 protection.” Johnson & Johnston Assocs. Inc. v. R.E. Serv. Co., 285 F.3d 1046, 1052 20 (Fed. Cir. 2002) (“[A] patent applicant defines his invention in the claims, not in the 21 [remainder of] the specification.”); Corning Glass Works v. Sumitomo Elec. U.S.A., 22 Inc., 868 F.2d 1251, 1257-58 (Fed. Cir. 1989) (“A claim in a patent provides the metes 23 and bounds of the right which the patent confers on the patentee to exclude others 24 from making, using, or selling the protected invention.”). 25 Although the claims alone define the scope of the invention, construing the 26 claims requires the Court to start with the language of the claims and also to look 27 elsewhere. The Federal Circuit’s en banc decision in Phillips v. AWH Corp., 415 F.3d 1 1303 (Fed. Cir. 2005) provides comprehensive instructions for navigating evidence 2 relevant to claim construction. The court begins with the language of the claims 3 themselves, which “provide substantial guidance as to the meaning of particular claim 4 terms.” Id. at 1314; Amgen Inc. v. Hoechst Marion Roussell, Inc., 457 F.3d 1293, 5 1301 (Fed. Cir. 2006) (citing Phillips for the proposition that “claim construction must 6 begin with the words of the claims themselves”). The Court should “generally give[] 7 [claim terms] their ordinary and customary meaning” in the eyes of a person of 8 ordinary skill in the art as of the filing date of the patent. Phillips, 415 F.3d at 1312-13 9 (quoting Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1582 (Fed Cir. 1996)). 10 In some cases, the ordinary meaning “may be readily apparent even to lay judges,” in 11 which case the claim construction “involves little more than the application of the 12 widely accepted meaning of commonly understood words.” Id. at 1314. 13 Beyond the claim language, the remainder of the specification is “always highly 14 relevant to the claim construction analysis.” Id. at 1315 (quoting Vitronics, 90 F.3d at 15 1582). The specification is dispositive when the inventor uses it to explicitly define a 16 claim term, in which case “the inventor’s lexicography governs.” Id. at 1316. But 17 even where the specification does not explicitly define a term, it may do so implicitly 18 (Id. at 1321) and in any event is a “concordance for the claims” (Id. at 1315 (citation 19 omitted)) on which the Court should “rely heavily.” Id. at 1317. At the same time, a 20 court must toe a fine line “between using the specification to interpret the meaning of a 21 claim and importing limitations from the specification into the claim.” Id. at 1323; see 22 also SciMed Life Sys., Inc. v. Advanced Cardiovascular Sys., Inc., 242 F.3d 1337, 23 1340 (Fed. Cir. 2001) (describing “reading a limitation from the written description 24 into the claims” as “one of the cardinal sins of patent law”). 25 The final source of “intrinsic evidence” bearing on claim interpretation is the 26 patent’s prosecution history. Phillips, 415 F.3d at 1317. The prosecution history 27 begins with the inventor’s application to the USPTO and includes all communication 1 between the inventor and the USPTO, culminating in the USPTO’s decision to issue 2 the patent. Vitronics, 90 F.3d at 1582. An inventor must often disclaim part of the 3 scope of an invention during prosecution to obtain a patent. Where the prosecution 4 history reflects a “clear and unmistakable disavowal of scope,” a court must construe 5 the claims accordingly. Purdue Pharma L.P. v. Endo Pharms., Inc., 438 F.3d 1123, 6 1136 (Fed. Cir. 2006). The court must recognize, however, that “the prosecution 7 history represents an ongoing negotiation between the PTO and the applicant,” and 8 thus “often lacks the clarity of the specification.” Phillips, 415 F.3d at 1317. It is 9 nonetheless useful for claim construction, although less so than the specification. Id. 10 Extrinsic evidence is always “less significant” and in general “less reliable” 11 than intrinsic evidence. Id. at 1318. Unlike intrinsic evidence, extrinsic evidence is 12 not “created at the time of patent prosecution for the purpose of explaining the patent’s 13 scope and meaning.” Id. The court has discretion to use extrinsic evidence in claim 14 construction, but need not do so. Id. at 1319. Indeed, where the intrinsic evidence is 15 adequate to define a claim term, “it is improper to rely on extrinsic evidence.” 16 Vitronics, 90 F.3d at 1583; Trilogy Commc’ns, Inc. v. Times Fiber Commc’ns, Inc., 17 109 F.3d 739, 744 (Fed. Cir. 1997) (“When . . . district court has concluded that the 18 patent specification and prosecution history adequately elucidate the proper meaning 19 of claims, expert testimony is not necessary and certainly not crucial.” 20 III. DISCUSSION 21 A. Disputed Claim Terms 22 The parties dispute the meaning of ten separate terms in the ‘858 Patent. 23 1.

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Treehouse Avatar LLC v. Valve Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/treehouse-avatar-llc-v-valve-corporation-wawd-2019.