Traxcell Technologies, LLC v. Sprint Communications Co., No. 20-1852 (Fed. Cir. 2021)Annotate this Case
Traxcell sued Sprint and Verizon for infringement of four patents related to self-optimizing wireless networks and to navigation technology. All share a specification and a 2001 priority date. After claim construction and discovery, the district court granted summary judgment for Sprint and Verizon. Summary judgment was based on several grounds. One claim was not infringed because Traxcell had not met the “way” prong of the function-way-result test in asserting an infringing structural equivalent to a means-plus-function limitation nor had Traxcell shown a genuine dispute about either the “location” limitation or the “first computer” and “computer” limitations in other claims. The district court held one claim indefinite for failure to disclose sufficient structure for a means-plus-function limitation. Traxcell could not show that the accused technology determined a wireless device’s location on the network itself, as claimed, rather than on the device.
The Federal Circuit affirmed, upholding the district court’s claim construction. Under that construction, Traxcell failed to show a genuine issue of material fact as to infringement and that several of Traxcell’s claims are indefinite.