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ARTICLE · 17 JUNE 2021

Statements Made In Litigation Can Support Prosecution History Estoppel

Finnegan, Henderson, Farabow, Garrett & Dunner LLP
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In Speedtrack, Inc. v. Amazon.com, Inc., Nos. 2020-1573, 2020-1660 (Fed. Cir. June 3, 2021), the Federal Circuit affirmed the District Court for the Northern District of California's final judgment of noninfringement based on claim construction.

United StatesIntellectual Property
Abhinav Garg
Abhinav Garg
Ji-Hye (Christina) Yang
Ji-Hye (Christina) Yang
Elizabeth Ferrill
Elizabeth Ferrill
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In Speedtrack, Inc. v. Amazon.com, Inc., Nos. 2020-1573, 2020-1660 (Fed. Cir. June 3, 2021), the Federal Circuit affirmed the District Court for the Northern District of California's final judgment of noninfringement based on claim construction.

Speedtrack's patent, U.S. Patent No. 5,544,360, is directed to a method of organizing computer files. The user assigns each file one or more category description, which is later used to locate the file. For example, a recipe file can be assigned "French," "Bread," and "Recipes," whereas the pertinent prior art, U.S. Patent No. 5,047,918 ("Schwartz"), has a hierarchical structure requiring an "attribute" such as "recipes" and a "value" such as "bread."

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