The Federal Circuit issued a precedential opinion last week
addressing how courts should interpret the ordering of steps in
method claims, affirming that grammatical structure and logical
dependencies in the claims can mandate a specific sequence even
without explicit ordering language.
In Sound View Innovations, LLC v. Hulu, LLC, decided
January 29, 2026, the court upheld summary judgment of
noninfringement, holding that claim 16 of U.S. Patent No. 6,708,213
(the "'213 patent") requires its first two steps to
be performed in order—a requirement Hulu's accused
products did not meet.
Background
The now-expired '213 patent covers methods for streaming
multimedia content over networks using intermediate "helper
servers" to cache and distribute content more efficiently.
Sound View alleged that Hulu infringed claim 16 by directing
third-party edge servers (the claimed "helper servers" or
HSs) to perform every step of the asserted claim.
