California Institute v. Broadcom Ltd., No. 20-2222 (Fed. Cir. 2022)
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Caltech’s patents disclose circuits that generate and receive irregular repeat and accumulate (IRA) codes, a type of error correction code designed to improve the speed and reliability of data transmissions. Wireless data transmissions are ordinarily susceptible to corruption arising from noise or other forms of interference. IRA codes help to identify and correct corruption after it occurs.
The Federal Circuit affirmed, in part, a judgment finding infringement. The district court did not err in its construction of the claim limitation “repeat” and substantial evidence supports the jury’s verdict of infringement of the asserted claims of the patents. The court upheld summary judgment findings of no invalidity based on inter partes review estoppel, a determination of no inequitable conduct, and the district court’s decision with respect to its jury instructions on extraterritoriality. The court remanded in part. Claim 13 of the 781 patent is patent-eligible but the court vacated the verdict of infringement because of the district court’s failure to instruct the jury on the construction of the claim term “variable number of subsets.” Caltech’s two-tier damages theory cannot be supported on the record, requiring a new trial on damages.
The court issued a subsequent related opinion or order on February 22, 2022.
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