Wednesday, November 13, 2013

Computer Docking Station Corp. v. Dell, Inc. case brief

Computer Docking Station Corp. v. Dell, Inc. case brief summary
519 F.3d 1366 (2008)

Plaintiff, the patentee of a type of portable computer, appealed from the entry of summary judgment of noninfringement by the United States District Court for the Western District of Wisconsin, entered in favor of defendants, alleged infringers who produced various computer devices, including laptops and docking stations. The alleged infringers appealed the denial of an award of attorney's fees under 35 U.S.C.S. § 285.

The patented invention was described by the terms "portable computer" and "portable computer microprocessing system" which limited the scope of the asserted claims. Rather than requiring a portable display and keyboard, the patented invention concentrated on portability of an exceptionally large memory capacity in hard disk drive.

  • During prosecution, the examiner rejected several claims as anticipated and obvious in view of a patented laptop computer and a docking module that facilitated operation on a desktop. 
  • The patentee thus had to disavow an interpretation of "portable computer" that would encompass a computer with a display or keyboard, which definition would include the alleged infringing laptop devices. 
  • Each of the accused laptop computers had a built-in display or keyboard. 
  • The court therefore affirmed the district court's holding of no infringement. 
  • However, the court also affirmed the finding that the case was not exceptional, and that attorney's fees were not warranted under 35 U.S.C.S. § 285. 
  • The patentee had acted reasonably and conducted the litigation in good faith.

The district court's grant of summary judgment of noninfringement, and its denial of attorney fees and costs, were affirmed.

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