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ARTICLE · 10 APRIL 2013

Joint Actors As It Relates To Method Claim Infringement

Addressing infringement of a method claim by one or two actors, the U.S. Court of Appeals for the Federal Circuit vacated a district court's grant of summary judgment of no infringement.

United StatesIntellectual Property

Addressing infringement of a method claim by one or two actors, the U.S. Court of Appeals for the Federal Circuit vacated a district court's grant of summary judgment of no infringement, but in doing so found no direct infringement and remanded on indirect infringement for consideration under its recent en banc decision in Akamai. Move, Inc. v. Real Estate Alliance Ltd., Case No. 12-1342 (Fed. Cir., Mar. 4, 2013) (Lourie, J.)

Real Estate Alliance Ltd. (REAL) holds a patent relating to methods for locating available real estate property using a zoom-enabled map. The claim required creating a database of available real estate properties; displaying a map of a geographic area; selecting a first area having boundaries within the geographic area; zooming into the first area to display a more detailed view of the selected first area; displaying the zoomed area; and then allowing further selecting, zooming and displaying of additional areas within the first selected area.

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