Court Focuses Narrowly on Claim Terminology in LogMeIn Patent Case

By Tanya Roth, Esq. on July 31, 2012 | Last updated on March 21, 2019

The Federal Circuit Court of Appeals remanded a patent infringement case back to the district court on Tuesday morning, finding that the district court didn't fully understand a claim term in the underlying patent.

The case was brought by a company called 01 Communique Laboratory Inc against LogMeIn Inc, reports Reuters.

The District Court for the Eastern District of Virginia granted summary judgment of non infringement to LogMeIn on U.S. Patent Number 6,928, 479.

The decision focused on the claim term "location facility."

The patent at issue dealt with a technology that allowed one computer to access another computer remotely, via the Internet.

The Federal Circuit Court of Appeals found that the district court understood the term "location facility" to mean a "device" whereas the Federal Circuit believed the term to refer to a software.

That distinction, the Federal Circuit held, was the key problem in the district court's opinion.

The district court held that a location facility must be contained on a single physical computer. It concluded that a location facility was a component of a locator server computer that performed four distinct functions.

Since these functions needed to be performed by one single physical computer, the district court found that LogMeIn was not in violation of the patent.

The Federal Circuit pointed out that the parties agreed that the location facility was software that ran on the locator server computer.

The arguments before the Federal Circuit focused largely on the language in the claims. LogMeIn argued that the use of the words "a" and "its" made reference to the fact that the locator computer was meant to be in the singular.

However, the Federal Circuit held that precedence established that the words "a" or "an" in a patent claim referred to "one or more." Nothing else in the language of the claim led the court to believe that the claim was intended to refer to a single computer.

The district court's decision was vacated and the case was remanded.

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