SAS Inst., Inc. v. ComplementSoft, LLC
United States Court of Appeals for the Federal Circuit
June 10, 2016, Decided
[*1343] [***1032] Stoll, Circuit Judge.
SAS Institute, Inc. filed an inter partes review ("IPR") petition with the Patent Trial and Appeal Board ("Board") to review the patentability of ComplementSoft's U.S. Patent No. 7,110,936. The Board instituted an IPR proceeding on some, but not all, of the '936 patent claims challenged in SAS's petition. The Board ultimately found all of the instituted claims, except for claim 4, unpatentable [**2] [***1033] in view of the prior art. SAS argues on appeal that the Board misconstrued a claim term and that the Board erred by not addressing in the final written decision claims SAS petitioned against, but that the Board did not institute as part of the proceeding. ComplementSoft cross-appeals two of the Board's claim constructions. For the reasons below, we agree with the Board on all of the challenged constructions and determine that the Board did not need to address in its final written decision claims it did not institute. We also vacate the Board's determination that claim 4 is patentable and remand so that the parties may address a new construction that the Board adopted in its final written decision after interpreting the claim differently before.
ComplementSoft is the assignee of the '936 patent, issued September 19, 2006, and directed to an "Integrated Development Environment for generating and maintaining source code . . . in particular, programmed in data manipulation languages." '936 patent col. 2 ll. 8-11. The patent characterizes a development environment as comprising a set of software tools allowing users to develop, edit, and debug software for a particular programming language or set [**3] of programming languages. Id. col. 1 ll. 32-48. The development environment contemplated by the '936 patent utilizes a graphical user interface and is particularly designed for data manipulation languages, including SAS®, which is developed by the appellant. Id. col. 1 l. 64 — col 2 l. 3, col. 2 l. 11. The specification describes that the development environment of the '936 patent serves three primary functions: (1) it allows users to locally edit code stored on a central server; (2) it detects a user's programming language and parses code accordingly; and (3) it generates representative visualization of such code, which can be directly edited to effect a change to the underlying code. Id. col. 2 l. 8 — col. 3 l. 20.
The specification describes that four major components of the '936 patent design environment are a document manager, an editor, a parser layer, and a visualizer. The document manager is a program that performs enhanced file management functions. Id. col. 6 ll. 22-42. The editor allows a user to edit and debug source code using standard text-editing functions. Id. col. 7 l. 3 — col. 8 l. 7. The parser layer examines source code, detects which programming language is being used in the code, and applies rules [**4] and logic corresponding to that programming language. Id. col. 9 ll. 38-53, col. 17 ll. 30-45. Finally, the visualizer works in conjunction with the parser layer to parse the code and display it graphically using icons connected with arrows. Id. col. 8 ll. 8-12.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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825 F.3d 1341 *; 2016 U.S. App. LEXIS 10508 **; 119 U.S.P.Q.2D (BNA) 1031 ***
SAS INSTITUTE, INC., Appellant v. COMPLEMENTSOFT, LLC., Cross-Appellant
Subsequent History: Rehearing denied by, Rehearing, en banc, denied by SAS Inst., Inc. v. Complementsoft, LLC, 842 F.3d 1223, 2016 U.S. App. LEXIS 20013 (Fed. Cir., Nov. 7, 2016)
US Supreme Court certiorari granted by SAS Inst. Inc. v. Lee, 137 S. Ct. 2160, 198 L. Ed. 2d 230, 2017 U.S. LEXIS 3236 (U.S., May 22, 2017)
Reversed by, Remanded by SAS Inst., Inc. v. Iancu, 2018 U.S. LEXIS 2629 (U.S., Apr. 24, 2018)
Prior History: [**1] Appeals from the United States Patent and Trademark Office, Patent Trial and Appeal Board in No. IPR2013-00226.
SAS Inst., Inc. v. ComplementSoft, LLC, 2014 Pat. App. LEXIS 4913 (Bd. Pat. App. & Interferences, Aug. 6, 2014)
Disposition: AFFIRMED-IN-PART, VACATED-IN-PART, AND REMANDED.
patent, graphical, manipulation, estoppel, depicting, diagram, Invents, reexamination, post-grant, partial, visualizer, retrieved, database, icons, path, map, invalidity, comprised, patentee, arrows, editor, edit, user, Innovation, disclaimer, threshold, display, parser, object-oriented, unpatentable
Patent Law, Jurisdiction & Review, Standards of Review, De Novo Review, Infringement Actions, Claim Interpretation, Fact & Law Issues, Substantial Evidence, Claim Interpretation, Administrative Law, Agency Adjudication, Formal Adjudicatory Procedure, Hearings, Business & Corporate Compliance, Patent Law, US Patent & Trademark Office Proceedings, Reexamination Proceedings