MasterObjects, Inc. v. Amazon.com, Inc.
- William Alsup
- 3:20-cv-08103
- U.S. District Court · Northern District of California
- 3
In MasterObjects v. Amazon, Judge Alsup clarified that summary judgment for Amazon covers all infringement theories, vacated trial, and ordered separate judgment.
MasterObjects, Inc. and Amazon.com, Inc.; the ruling ends the scheduled pretrial conference and trial and confirms summary judgment for Amazon on all infringement theories.
What happened
MasterObjects, Inc. v. Amazon.com, Inc. concerns Amazon’s summary-judgment win on patent infringement. The court had previously ruled that Amazon did not infringe, and then asked the parties to address the separate theory that Amazon’s products were equivalent to the claimed inventions.
MasterObjects had opposed Amazon’s motion only under a literal-infringement theory, not under the doctrine of equivalents. The court said that failure waived that theory at summary judgment. It also found that MasterObjects lacked the expert testimony and other evidence needed to prove equivalent infringement under the court’s claim construction.
The court clarified that the earlier summary judgment for Amazon covers every infringement theory, including the doctrine of equivalents. Judge Alsup vacated the final pretrial conference and trial, and stated that separate judgment would follow.
The detailed version
- MasterObjects, Inc. v. Amazon.com, Inc. · No. 3:20-cv-08103
- William Alsup
- Sept. 22, 2022
Background
The court had previously granted Amazon summary judgment of noninfringement as to all claims in the case. The parties’ briefing and oral argument addressed only literal infringement, even though the operative pleading referenced the doctrine of equivalents for the patents at issue. The earlier summary-judgment order therefore requested additional statements about that doctrine.
Analysis
The court explained that MasterObjects opposed Amazon’s summary-judgment motion only on literal-infringement grounds. Because a party opposing summary judgment must present all grounds for its opposition, the court treated MasterObjects’ failure to raise the doctrine of equivalents as a waiver of that theory at the summary-judgment stage.
The court also held that the existing record independently supported summary judgment of noninfringement under the doctrine of equivalents. A patent owner bears the burden of producing evidence of infringement under that doctrine. MasterObjects had not presented arguments or evidence addressing the doctrine under the claim construction adopted in the earlier order. Its expert, Peck, provided no permissible opinion concerning the cache limitations under that construction. The court further concluded that fact-witness examinations could not supply the required comparison between Amazon’s system and the claimed system by a person of ordinary skill in the art.
The court stated that evidence and argument concerning the doctrine of equivalents cannot simply be included within a case for literal infringement. Because MasterObjects could not prove infringement under the doctrine of equivalents, summary judgment of noninfringement was appropriate on that basis as well.
Disposition
The court clarified that the prior order granting Amazon summary judgment includes summary judgment of noninfringement on the doctrine of equivalents and, therefore, on all infringement theories. The court stated that separate judgment would follow and vacated the final pretrial conference and trial. The order was entered by Judge William Alsup.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.