Azure Networks, LLC v. CSR, PLC, No. 13-1459 (Fed. Cir. 2014)Annotate this Case
Plaintiffs sued for alleged infringement of the 129 patent, entitled “Personal Area Network with Automatic Attachment and Detachment.” The patent describes a network for wireless communications between a central hub device and a number of surrounding peripheral devices in close proximity with the hub device. The specification details the use of “a wireless personal area network [PAN] that permits a host device to communicate with a varying number of peripheral devices with minimal interference from neighboring networks. The district court dismissed plaintiff Tri-County for lack of standing, finding that Tri-County had effectively assigned the patent to Azure. The court also construed the term “MAC address” in the patent as “a device identifier generated by the hub device” and not, as Azure and Tri-County suggested, “an address that uniquely identifies a device or group of devices on a shared communication medium.” Azure stipulated to a judgment of noninfringement. The Federal Circuit affirmed the dismissal of Tri-County, but vacated and remanded in part, holding that the district court improperly construed the term.