Patent Case Summaries | Week Ending February 16, 2024 | Alston & Bird
Promptu Systems Corp. v. Comcast Corp., et al., No. 2022-1939 (Fed. Cir. (E.D. Pa.) Feb. 16, 2024). Opinion by Taranto, joined by Moore and Prost.
Promptu sued Comcast for infringing three patents directed to speech-recognition systems for either delivering cable or video content in response to a user’s speech request or controlling a television set based on a user’s speech command. The district court construed the claims largely according to Comcast’s proposals. The parties then stipulated to noninfringement, and the district court entered final judgment for Comcast.
On appeal, Promptu challenged the district court’s construction of four claim limitations: “back channel,” “multiplicity of received identified speech channels,” “speech recognition system coupled to a wireline node,” and “centralized processing station.” The Federal Circuit vacated the final judgment, reversed in part and affirmed in part the claim constructions, and remanded.
For “back channel,” the Federal Circuit ruled that the district court erred by limiting the term to “a fixed band of frequencies or time slot(s) for transmitting signals to a speech processing system or engine.” The Federal Circuit ruled that “nothing in the claim language suggests the limitation to a fixed band of frequencies or time slots.” Nor did the patent’s specification require “the particular path-definition technique demanded by the district court’s claim construction.” The court thus reversed the construction, as using “a fixed frequency band or time slots, in this patent, is no more than exemplary, not required.”
The Federal Circuit next reversed the construction of “multiplicity of received identified speech channels” for largely the same reasons. The Federal Circuit stated that the construction “depends on the underlying construction of ‘channel,’ which we have rejected.”
For the phrase “speech recognition system coupled to a wireline node,” the Federal Circuit ruled that the district court’s construction “incorrectly construes the constituent terms ‘speech recognition system,’ ‘coupled to,’ and ‘wireline node’ within the claim phrase.” The district court improperly narrowed “speech recognition system” to exclude any functionality beyond speech recognition. The Federal Circuit decided not to “go further to find words for a proper construction to replace the one we reject,” as the parties had not adequately explored alternatives, which “should take place on remand, to the extent necessary.” The Federal Circuit emphasized that “a claim construction, if needed at all, should help resolve, not add to, uncertainty in the understanding the finder of fact is to use in applying a claim term.”
The Federal Circuit also interpreted “coupled to” to mean “connected to,” reversing the district court’s meaning of “connected in or near,” which “incorrectly reads a proximity requirement (‘in or near’) into the claim term.”
The Federal Circuit next ruled that “the district court improperly adopted the specification’s definition of ‘centralized wireline node’ when construing the claim term ‘wireline node.’” The Federal Circuit explained that the “centralized” modifier used in the term defined in the specification “must add some meaning to or limitation on the ‘wireline node’ being modified.” The claimed “wireline mode” “must be broader in some way.”
Lastly, for the term “centralized processing station,” the district court’s construction included both a location requirement— that the station is located “at a cable-TV network head-end unit”—and a function requirement—that the station itself “performs voice recognition on voice commands.” The Federal Circuit affirmed the function requirement but reversed the location requirement. The court explained that “it is clear that a ‘head-end unit’ and a ‘centralized processing station’ are different things.”
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