SpeedTrack, Inc. v. Amazon.com, Inc., No. 20-1573 (Fed. Cir. 2021)
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SpeedTrack’s 360 patent discloses a “computer filing system for accessing files and data according to user-designated criteria.” The patent explains that prior-art systems “employ a hierarchical filing structure” and “emulate[] commonly[ ]used paper filing systems” in that they “organize[] data into files (analogous to papers in a paper filing system) and directories (analogous to file folders and hanging files).” According to the patent, such systems could “become[] very cumbersome.” According to the patent, prior-art solutions presented additional drawbacks. The 360 patent discloses a method that uses “hybrid” folders, which “contain those files whose content overlaps more than one physical directory” and “allows total freedom from the restrictions imposed by hierarchical and other present-day computer filing systems.”
SpeedTrack sued various retail website operators, alleging infringement of the patent. The Federal Circuit affirmed the stipulated judgment of noninfringement based on the district court’s construction of the term “hierarchical limitation.”
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