PATENTS - Nazomi v. Nokia

PATENTS - Software, and functionality requirements in device claims

Nazomi v. Nokia and Amazon and Vizio, et al.

Finding non-infringement because, among other reasons:

Here ... the claims do not cover hardware that contemplates an environment where it could be combined with software, but rather require a hardware-software combination that must perform the described functions.

The court described the claim requirements:

The need  [in the claims of the patent] for  the  specified  functionality  is confirmed by the  ’362 patent specification,  which indicates that “the [Java] hardware  accelerator can convert the stack-based Java bytecodes into . . . register-based native instructions on a CPU.” ’362 patent col. 2 ll. 23-25. The specification also explains that “[t]he Java hardware accelerator can do[] some or all of the following tasks,” and lists functions involved in processing stack-based instructions, including “managing the Java stack on a register file” and “generating exceptions on instructions on predetermined bytecodes,” mirroring the
limitations in claims 48 and 74.  ’362 patent col. 3 ll. 10-19; see, e.g., ’362 patent col. 11 ll. 5-6, col. 12 ll. 33-37. Contrary to Nazomi, there is nothing improper in construing device claims to require particular functionality. [citations omitted.]