Digest of Info-Hold, Inc. v. Applied Media Tech. Corp., No. 2013-1528, (Fed. Cir. Apr. 24, 2015) (precedential). On appeal from S.D. Ohio. Before Reyna, Wallach, and Taranto.
Procedural Posture: CAFC reversed and remanded.
- Claim Construction: The district court erred in limiting the meaning of the term “transmit” to server-initiated communications. In a de novo review of the intrinsic record, the CAFC found no evidence that required limiting the meaning of “transmit” to only server-initiated communications in lieu of its broader plain and ordinary meaning. The CAFC also determined that although the district court mentioned extrinsic evidence, it had not relied on that extrinsic evidence in construing of any of the terms in dispute. Thus, the CAFC reversed and remanded the district court’s ruling construing “transmit” and other related terms.