This morning the Federal Circuit released two nonprecedential opinions and one nonprecedential order. The first opinion affirms a judgment of a district court in a patent infringement case. The second affirms another judgment of a district court in another patent infringement case. The order is a dismissal. Here are the introductions to the opinions and a link to the order.
Esignature Software, LLC v. Adobe Inc. (Nonprecedential)
Esignature Software, LLC (“Esignature”) sued Adobe Inc. (“Adobe”) for infringing U.S. Patent No. 8,065,527 (“the ’527 patent”). The district court held the ’527 patent’s claims ineligible for patenting under 35 U.S.C. § 101 and, as a result, granted Adobe’s motion for judgment on the pleadings. Esignature appeals. We affirm.
Impact Engine, Inc. v. Google LLC (Nonprecedential)
In the action now before us, Impact Engine, Inc. alleges infringement by Google LLC of a family of Impact Engine’s patents. Several orders of the district court are central to addressing the disputes on appeal. First, the district court entered two claim-construction orders: one that, e.g., construed “compiling engine” to reflect the ordinary meaning of “compiler,” Impact Engine, Inc. v. Google LLC, No. 19- cv-01301, 2021 WL 5541942, at *4 (S.D. Cal. Feb. 5, 2021) (First Claim Construction Order); the other that construed “project viewer” elements in several asserted claims to be means-plus-function elements under 35 U.S.C. § 112(f), Impact Engine, Inc. v. Google LLC, No. 19-cv-01301, 2021 WL 9525522, at *3 (S.D. Cal. May 14, 2021) (Supplemental Claim Construction Order). Second, acting under Fed. R. Civ. P. 12(c), the district court held some asserted claims to be invalid under 35 U.S.C. § 101. Impact Engine, Inc. v. Google LLC, No. 19-cv-01301, 2021 WL 5234415, at *3–6 (S.D. Cal. Nov. 10, 2021) (Rule 12(c) Order). Third, acting under Fed. R. Civ. P. 56, the district court held that (a) additional asserted claims are invalid under § 101, (b) Impact Engine had presented no basis on which a reasonable jury could find infringement of two asserted claims containing the “project viewer” phrase, and (3) one asserted claim is invalid under § 112(a)’s written-description and enablement requirements. Impact Engine, Inc. v. Google LLC, 624 F. Supp. 3d 1190, 1193–96 (S.D. Cal. 2022) (Summary Judgment Order). Under those rulings, all asserted claims were either invalid or not infringed, so the district court entered final judgment for Google. Impact Engine appeals. We have jurisdiction under 28 U.S.C. § 1295(a)(1), and we affirm.