Motorola Mobility LLC, v. Int’l. Trade Com’n

Apple’s method of communicating changes in its devices’ registry of applications capable of receiving push notifications to a network did not infringe Motorola’s patent covering a method of communicating changes in the registry of installed applications to a network.

Opinion (Reyna): Motorola Mobility, Inc. ("Motorola") sought an injunction from the International Trade Commission ("ITC") prohibiting the importation of certain Apple, Inc. ("Apple") products alleging that those products’ use of push notifications infringed one of Motorola’s patents. The Motorola’s patent at issue, Pat. No. 6,272,333, covers a method and apparatus for controlling the delivery of data to mobile devices. The patent requires a device that maintains a registry of applications installed on the device which communicates that list to a fixed network and updates that network each time the registry of installed applications changes. The patented invention helps ensure that network resources are not wasted sending information to the device that the device cannot use. The Apple devices implement the accused functionality by maintaining a registry (on the device) of installed applications, and a second registry of applications using push notifications. When there is a change to registry of applications using push notifications, that change is communicated to the network but does not change the registry of installed applications. The administrative law judge denied Motorola’s motion for an injunction, holding that Apple’s products did not infringe the patent. The Commission affirmed the ALJ. Motorola appealed the ITC’s rejection to the Federal Circuit. To determine whether an accused product infringes, a court compares the accused product with the patent claims. Where the product does not fit within the patent’s claims it does not infringe. Because Apple’s products did not communicate changes in the registry of installed applications to the network, their operation fell outside the bounds of Motorola's patent. Accordingly, the Federal Circuit AFFIRMED the decision of the Commission.