United States Federal Circuit
Trading Technologies International v. Open E Cry, LLC, 12-1583
Summary judgment for defendants in patent infringement action related to software used for electronic trading on a commodities exchange, is reversed and remanded, where: 1) the district court erred when it held that the claims of plaintiff's patents were invalid for failure to comply with the written description requirement of 35 U.S.C. section 112 without considering the scope of the claims in light of the underlying disclosures; and 2) the claims of plaintiff's '055 patent, unlike those of the related '132 and '304 patents, need not be limited to displays with price axes capable only of manual re-centering, whether by prosecution disclaimer or prosecution history estoppel.
Appellate Information
- Decided 08/30/2013
- Published 08/30/2013
Judges
- LOURIE
Court
- United States Federal Circuit