BE Labs, Inc. v. Ubiquiti Networks, Inc.

Background

The court held a claim-construction hearing on April 8, 2025. Claim construction is the process of determining what patent-claim language means. Ubiquiti acknowledged that the “core dispute” was whether broadcasting could ever allow “two-way traffic.”

Parties’ Arguments and the Earlier Patent Proceeding

Ubiquiti relied on the patent’s prosecution history and statements BE Labs made during an appeal to the Patent Trial and Appeal Board (PTAB). Ubiquiti argued that the doctrine of prosecution disclaimer prevented BE Labs from interpreting the invention broadly enough to include two-way traffic. That doctrine can limit a patent owner from later asserting a claim interpretation that the owner disclaimed during the patent-application process.

The opinion discussed a July 15, 2009, PTAB decision reversing the examiner’s rejection of what became Patent ’581. The PTAB decision described the examiner’s interpretation of “broadcasting” and rejected BE Labs’s argument for a narrower interpretation, stating that it did not hold that independent claim 1 was limited to one-way communication. The court also cited authority stating that statements rejected by the Patent Office do not create a prosecution disclaimer.

Order

Judge Lorna G. Schofield ordered Ubiquiti to submit, by April 18, 2025, a letter no longer than two pages addressing how the PTAB decision rejecting BE Labs’s narrow reading of the claim language affects Ubiquiti’s prosecution-disclaimer arguments. The opinion is an interim order requesting supplemental briefing; it does not state a final ruling on the scope or meaning of the patent claims.