PROMPTU SYSTEMS CORPORATION v. COMCAST CORPORATION , No. 22-1939 (Fed. Cir. 2024)
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Promptu Systems Corp. sued Comcast Corp. alleging that Comcast infringed on its U.S. Patent Nos. 7,047,196 and 7,260,538. The patents cover a method of using speech recognition services in combination with cable television or video delivery. The case was litigated in the United States District Court for the Eastern District of Pennsylvania. The district court adopted claim constructions that were mostly in line with Comcast's proposals. As a result, Promptu and Comcast agreed to dismiss Promptu's patent-infringement claim and state-law claims with prejudice. Promptu also agreed to a final judgment of no infringement by Comcast of the ’196 and ’538 patents, based on the claim constructions adopted by the district court.
Promptu appealed the judgment, challenging several of the underlying claim constructions. The United States Court of Appeals for the Federal Circuit found that the district court incorrectly construed certain claim terms and therefore vacated the judgment and remanded the case for further proceedings. The court held that the district court's constructions of the terms "back channel," "multiplicity of received identified speech channels," "speech recognition system coupled to a wireline node," and "centralized processing station" were not accurate. The court provided detailed analysis and reasoning for these conclusions. The court did not rule on the merits of the infringement claims, but instead remanded the case for further proceedings based on the corrected claim constructions.
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