DCT

1:05-cv-00333

Board Of Regents v. Mitsubishi Electric

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Key Events
Complaint

I. Executive Summary and Procedural Information

Case Timeline

Date Event
1985-09-06 U.S. Patent No. 4,674,112 Priority Date
1987-06-16 U.S. Patent No. 4,674,112 Issue Date
2005-05-06 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 4,674,112 - "Character Pattern Recognition and Communications Apparatus"

  • Patent Identification: U.S. Patent No. 4674112, issued June 16, 1987.

The Invention Explained

  • Problem Addressed: The patent's background section describes the difficulty and inefficiency of non-verbal communication using standard 12-key telephone keypads, where most keys represent three different letters. It identifies the need for multiple keystrokes to specify a single letter as a "major impediment to effective telecommunication" (ʼ112 Patent, col. 1:47-52).
  • The Patented Solution: The invention is an apparatus that allows a user to input a word by depressing a single key for each letter, creating an inherently ambiguous sequence of key presses. A controller then receives this ambiguous "word code" and matches it against a stored vocabulary of "syllabic elements" (e.g., prefixes, suffixes, letter groups) to reconstruct and display the intended word (ʼ112 Patent, Abstract; col. 2:53-65). This process resolves the ambiguity of the limited keypad without requiring multi-tap input from the user.
  • Technical Importance: The approach sought to enable faster and more intuitive text entry on ubiquitous 12-key pads, a significant usability improvement for early digital communication devices (ʼ112 Patent, col. 4:21-28).

Key Claims at a Glance

  • The complaint does not specify which claims it asserts, but independent claims 1 (an apparatus claim) and 10 (a method claim) are central to the invention.
  • Independent Claim 1 recites an apparatus comprising:
    • "receiving means" for receiving tones from a keypad and decoding them into codes, where each tone is ambiguous as to the specific letter.
    • "controller means" for processing the codes.
    • "recognition means" for matching the codes with a programmed sequence.
    • The recognition means includes a "stored vocabulary comprising a plurality of syllabic elements" used for the matching.
    • "indicating means" (e.g., a display) to communicate the resulting word to the user.
  • Independent Claim 10 recites a method comprising the steps of:
    • "inputting a word" by "depressing a single key for each alphabetic character".
    • "transmitting signals" generated by the key depressions.
    • "receiving" and "decoding" the signals into binary code.
    • "matching" the binary code with pre-programmed codes representing a "syllabic element".
    • "Forming a representation of the word" from the matched syllabic elements.
    • "outputting" the word representation to a user.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint accuses a vast number of mobile phone models sold by the nine defendants, including, for example, the Mitsubishi "M760," Motorola "i860," Nokia "6019i," Panasonic "EB-G51," Philips "330," and Samsung "SPH-i700" (Compl. ¶¶ 18-24).

Functionality and Market Context

  • The complaint does not describe the specific functionality of the accused products. It alleges that the devices "fall within the scope of the claims of the '112 Patent" (Compl. ¶¶ 18-24). The accused products are mobile phones from an era where predictive text technologies (such as T9) were a key feature for facilitating text messaging on a standard 12-key numeric keypad. This technology allowed users to press each number key only once per intended letter, with the device's software predicting the intended word from a dictionary.
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or a detailed, element-by-element infringement analysis. The infringement allegations consist of identifying the accused mobile phones and asserting that they infringe the ’112 Patent (Compl. ¶¶ 18-24). A potential infringement theory, based on the likely functionality of the accused products, may connect the claims to the products as follows:

A user typing "HELP" on an accused phone would press "4-3-5-7." This action could be argued to meet the "inputting a word into said keyboard by depressing a single key for each alphabetic character" step of claim 10. The phone’s processor and software would function as the "receiving means" and "controller means" of claim 1, which "decodes" the key presses. The phone's predictive text software, which compares the ambiguous "4357" sequence against an internal dictionary to find "HELP," could be alleged to be the claimed "recognition means" that performs the "matching" step. The dictionary itself could be argued to be the "stored vocabulary", and the resulting word displayed on the screen would be the "outputting" step.

Identified Points of Contention

  • Technical Questions: A primary question will be whether the algorithms in the accused products function as claimed. For instance, does the defendants' software rely on matching "syllabic elements" as taught in the patent, or does it use a different method, such as a whole-word frequency-based dictionary? The patent emphasizes using syllabic elements to minimize memory requirements ('112 Patent, col. 5:4-10), which raises the question of whether accused products with more advanced hardware and larger memories operate on a fundamentally different technical principle.
  • Scope Questions: The limitation "depressing a single key for each alphabetic character" (ʼ112 Patent, col. 8:65-67) is a potential point of dispute. The infringement analysis may depend on whether the accused phones exclusively use this method or also incorporate other modes, such as multi-tap, and how that affects the infringement analysis for the system as a whole.

V. Key Claim Terms for Construction

The Term: "syllabic elements"

  • Context and Importance: This term is the core of the patented ambiguity-resolution technique. The patent’s validity and the scope of its infringement read will likely depend heavily on this term's construction. Practitioners may focus on this term because the plaintiff will likely argue for a broad interpretation that covers the word-prediction dictionaries in the accused products, while defendants may argue for a narrower definition that their products do not meet.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification explicitly defines the term broadly, stating the vocabulary "includes common letter-groups, suffixes, prefixes, single letters, and a few complete words, genericly referred to as 'syllabic elements.'" (ʼ112 Patent, col. 5:8-12). This language may support a construction covering any stored character string used for matching, not just linguistic syllables.
    • Evidence for a Narrower Interpretation: A defendant could argue that the term's plain meaning implies a connection to phonetic syllables. Further, a defendant might argue that the patent’s repeated emphasis on reconstructing words from these elements ('112 Patent, col. 2:62-65) distinguishes it from systems that simply match an input sequence to a list of whole words.

The Term: "depressing a single key for each alphabetic character"

  • Context and Importance: This phrase appears in method claim 10 and defines the specific user action covered by the patent. It is critical for distinguishing the invention from prior art "multi-tap" systems and will be a focal point for determining whether the accused products' mode of operation infringes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint does not provide a basis for a broader interpretation. A plaintiff might argue that as long as the device offers a single-press mode that functions as claimed, the presence of other modes is irrelevant to an infringement finding for that mode.
    • Evidence for a Narrower Interpretation: The plain language of the claim appears to be a strict limitation. The patent consistently contrasts its "single keystroke" method with prior art that required "multiple keystroke entries" ('112 Patent, col. 1:43-45), suggesting the "single key" limitation was a deliberate and defining feature of the invention.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants induced and contributed to infringement under 35 U.S.C. §§ 271(b) and (c) (Compl. ¶25). This allegation is based on the assertion that the "infringing products have no substantial non-infringing uses," but the complaint does not provide specific factual allegations regarding, for example, user manuals or other evidence of intent to induce.
  • Willful Infringement: The complaint does not contain an allegation of willful infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

  1. A central issue will be one of technical mechanism: Do the accused products' predictive text systems operate by "matching" an input code against a vocabulary of "syllabic elements" to "form" a word as claimed, or do they employ a technically distinct method of whole-word lookup that falls outside the patent's scope?
  2. The case will likely turn on a question of definitional scope: Can the term "syllabic elements", as defined and used in the patent, be construed to read on the full-word dictionaries and frequency algorithms likely used in the accused products, or is it limited to the memory-saving, prefix/suffix-based system described in the specification?
  3. A key evidentiary question will be one of infringing use: Can the plaintiff demonstrate that the accused devices practice the specific method of "depressing a single key for each alphabetic character" and that this mode of operation, in and of itself, meets all limitations of the asserted method claims?