Federal Circuit Says No To $626M Patent Verdict Against Apple

September 5, 2012, by Mandour & Associates, APC

 Orange County — The Federal Circuit on Tuesday affirmed a lower court’s order chucking out a $626 million jury verdict against Apple Inc. in Mirror Worlds LLC’s suit alleging Apple’s Mac OSX Tiger, Leopard and Snow Leopard operating systems infringed its patented technology for searching, displaying and archiving computer files.

Mirror Worlds, founded by Yale professor David Gelernter, sued Apple in 2008 alleging direct and induced infringement of twelve claims of three patents: U.S. Patent Numbers 6,006,227, 6,638,313 and 6,725,427. The patents disclose a “document streaming” operating system that, unlike traditional operating systems, identifies documents with a time stamp instead of a file name and maintains them in chronologically ordered “streams.” The case focused on Apple’s Time Machine, Spotlight and Cover Flow features of its operating systems.

At the conclusion of Mirror Worlds’ case in chief, the district courtgranted Apple’s oral motion for judgment as a matter of law that Apple did not induce infringement of any of the patents. Mirror Worlds did not offer any evidence of actual performance of the patented method by third parties, the district court ruled.

The issue of direct infringement by Apple was submitted to the jury, which found Apple liable for willfully infringing all three asserted patents and awarded $208.5 million in damages for each of the three patents.

After the trial, the district court granted Apple’s motion for judgment as a matter of law, vacated the jury verdict and concluded that Mirror Worlds failed to present substantial evidence of direct infringement and damages.

In particular, the district court concluded that Mirror Worlds did not establish infringement of the asserted claims of the ’313 and ’427 patents under the doctrine of equivalents — its only infringement theory for those patents — because the accused products did not have an equivalent of a “cursor or pointer.”

The district court also concluded that Mirror Worlds failed to offer substantial evidence that Apple performed each step of the claimed methods of the ’227 patent, and that the evidence presented at trial was not sufficient to support the damages award.

“The necessary evidence was not put before the jury to support the verdict of infringement or damages,” the Federal Circuit said in affirming the lower court’s rulings.