Short Summary: Claim construction and infringement rulings affirmed.

Case: United Video Props., Inc. v. Amazon.com, Inc., No. 2013-1396 (Fed. Cir. April 8, 2014) (non-precedential). On appeal from D. Del. Before Lourie, Mayer, and Chen.

Procedural Posture: Plaintiffs appealed district court’s claim construction ruling and its judgment of non-infringement. CAFC affirmed.

  • Claim Construction – Prosecution Disclaimer: During prosecution, the claims were amended to remove the terms “Internet delivered data” to overcome a rejection for lack of written description under 35 U.S.C. § 112, ¶ 1. The district court correctly held that the patentee disclaimed “Internet delivered data” from the claim scope during prosecution.
  • Claim Construction: District court correctly held that the specification and the drawings show that the claim term “interactive program guide” is concerned with forward-looking, scheduled programming.