Digest of Azure Networks, LLC v. CSR PLC, No. 2013-1459 (Fed. Cir. Nov. 6, 2014) (precedential). On appeal from E.D. Tex. Before Reyna, Mayer, and Chen.

Procedural Posture: Plaintiffs-appellants Azure and Tri-County appealed the district court’s dismissal of Tri-County for lack of standing, as well as a stipulated judgment of noninfringement based on the district court’s alleged error in construing the claim term “MAC address.” The Federal Circuit affirmed the dismissal of Tri-County, but reversed the construction of “MAC address,” vacated the judgment of noninfringement and remanded.

  • Standing: Tri-County’s grant of an exclusive license to practice the patent-in-suit, as well as the exclusive right to enforce the patent, constituted an assignment. Tri-County reserved no right to control, veto, or be notified of Azure’s licensing or litigation activities, and was obligated to cooperate in litigation at Azure’s discretion. Therefore, Tri-County lacked standing to join the suit as a co-plaintiff.
  • Claim Construction: The term “MAC address” is a well-established term of art that includes universally and locally administered addresses. The specification and prosecution history failed to clearly redefine the term or exclude universal addresses, and thus the plain meaning of the term prevailed, notwithstanding the fact that the examples used only locally administered addresses.

Mayer, dissenting in part:

Claim Construction: Because the “MAC addresses” in the patent examples are exclusively locally administered, and construction of the term to include universal addresses would render the claims invalid, the term covers only locally administered addresses.