Facebook, Inc. v. BlackBerry Limited

Background

Facebook alleged that BlackBerry Limited and BlackBerry Corporation infringed six Facebook patents: U.S. Patent Nos. 6,356,841, 6,744,759, 7,228,432, 7,302,698, 7,567,575, and 8,429,231. The patents concern GPS management, user-configured telephone service over a data network, computer security, trusted computing states, mobile multimedia services, and voice instant messaging. After a technology tutorial, written submissions, and a hearing under the claim-construction procedure described in Markman v. Westview Instruments, the court construed six disputed terms. Claim construction determines the meaning and scope of patent claims before other infringement issues are decided.

Claim Constructions

U.S. Patent No. 6,356,841: “central location”

The court construed “central location” as “an integrated set of components that receives, stores, and analyzes G.P.S and other data from one or more remote unit.” The court rejected Facebook’s broader proposed meaning, which would have included any location that communicates with a remote unit and differs from it. The court held that the term requires centralized communication and data-processing functions but does not require one physical building or geographically fixed place.

U.S. Patent No. 6,744,759: “data network telephone”

The court construed “data network telephone” as “a fixed communication device with a communications interface for connection to a data network.” Although the court recognized that the words might otherwise suggest a telephone that works with a data network, it found that the patent’s claims, specification, and prosecution history limit the term to a fixed device rather than a mobile telephone.

U.S. Patent No. 7,302,698: “operating state” and “operational state”

The court found that “state,” “operating state,” and “operational state” are used interchangeably in the patent. It construed them as “a mode of operation of the computing entity in which a plurality of functions provided by the computing platform may be carried out.” The construction does not include operating systems. The court rejected BlackBerry’s proposed additional requirements that the state be running on the computing entity and be distinguishable from other states using integrity metrics.

U.S. Patent No. 7,567,575: “multimedia data delivery information”

The court rejected BlackBerry’s argument that the term was indefinite. Indefiniteness means that a patent claim does not tell skilled readers the scope of the invention with reasonable certainty. The court found that the phrase’s individual words allowed a person skilled in the field to understand its meaning with reasonable confidence. It construed the term as “information related to the delivery of multimedia data.”

The court also construed “mobile device transmission profile” as “a profile containing information about transmission characteristics of a mobile device, including the wireless protocol and the wireless channel environment of the mobile device.” The court concluded that information about the wireless channel environment was necessary to the adaptation of multimedia transmission described in the patent.

U.S. Patent No. 8,429,231: “generic signaling interface channel”

The court found that “generic signaling interface channel” was a coined term without an established meaning outside the patent. It construed the term as “a channel used to establish an initial connection in which local IP addresses are exchanged if the parties permit such an exchange and then is no longer used.”

Disposition

The court adopted the stated constructions of all six disputed terms. It ordered the parties to submit a further joint case-management report and set a further case-management conference for February 7, 2020. The opinion did not resolve whether BlackBerry infringed any patent or decide the ultimate merits of Facebook’s infringement claims.