Profectus Tech., LLC v. HuaweiI Techs. Co., Ltd., No. 15-1016 (Fed. Cir. 2016)
Annotate this CaseProfectus’s patent discloses a mountable digital picture frame for displaying still digital images. The specification discusses how a user can display digital images on a wall or desktop similar to conventional photographs. Profectus sued manufacturers and sellers of tablet computer devices. After construing the term “mountable,” the district court granted summary judgment of noninfringement on grounds that the accused devices do not satisfy the “mountable” limitation. The Federal Circuit affirmed. Although certain intrinsic physical features may combine to aid in mounting with external components, those features must be for mounting to meet the claim limitations. While the accused devices are capable of mounting by exploiting the communication ports and being easy to prop up due to their size and weight, those characteristics do not make the accused devices mountable as claimed and fail to raise a genuine dispute of material fact as to whether features for mounting (or their equivalents) are present within the accused devices.
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