Wi-LAN Inc. v. Sharp Electronics Corp., No. 20-1041 (Fed. Cir. 2021)Annotate this Case
Wi-LAN’s 654 patent concerns “methods to display interlaced video on [a] noninterlaced monitor” Interlaced video. Television sets use interlaced video formats to prevent a “flicker” effect that results from the difference in the frame rate of the television set and the frame rate in which a program was filmed. Wi-LAN’s 250 patent, “relates generally to multimedia encoders and specifically [to] an integrated multimedia stream multiplexer,” which receives separate audio and video data streams and combines them into a single multimedia data stream. The 250 patent is directed to a system for dynamically adjusting the bit rates of the input audio and video data streams to obtain a combined multimedia data stream with an optimal bit rate. Vizio and Sharp sold “smart” television sets. Wi-LAN alleged direct and induced infringement of the patents against both.
For the 250 patent, the district court construed the terms “output multimedia data stream” and “a multimedia processor, coupled to the data rate analyzer” and entered a stipulated judgment of noninfringement. The court reasoned that Wi-LAN knew that it could not establish infringement without establishing that the source code of Sharp’s and Vizio’s systems actually practiced the patented method and lacked sufficient admissible evidence to prove direct infringement of the 654 patent. The Federal Circuit affirmed, upholding the construction of the claim terms. With respect to the 654 patent, a source code printout did not constitute a business record admissible under Rule 803(6).