Microsoft Corp. v.Proxyconn, Inc., No. 14-1542 (Fed. Cir. 2015)Annotate this Case
The 717 patent relates to a system for increasing the speed of data access in a packet-switched network, making use of “digital digests” that act as short digital fingerprints for the content of their corresponding documents. By communicating the smaller digital digests in place of the documents themselves, the invention reduces the redundant transmission of data throughout the network. On inter partes review, the Patent Trial and Appeal Board concluded that all of the challenged claims except claim 24 were unpatentable as anticipated under 35 U.S.C. 102 alone or additionally as obvious under 35 U.S.C. 103. The Federal Circuit reversed the Board’s constructions of the term “gateway . . . between at least two other computers” in claims 6, 7, and 9 and the terms “sender/computer” and “receiver/computer” in claims 1, 3, 10, 22, and 23, and remanded its unpatentability determinations of those claims. The court affirmed the construction of the “searching” limitation in claim 22, the determination that claim 24 is patentable, the conclusion that claims 11, 12, and 14 were anticipated, and the Board’s denial of the patent owner’s motion to amend claims 1 and 3.