PalmPilot's "Graffiti" System May Infringe Xerox Patent

Case: Xerox Corp. v. 3Com Corp. et al, Case No. 04-1470 (Fed. Cir. 6/8/06)

The One Sentence Summary: Federal Circuit reverses summary judgment of invalidity based on anticipation, obviousness and indefiniteness.

What They Were Fighting About: Patent infringement defendant sought to invalidate Xerox's patent on a system for interpreting handwritten text as being invalid in light of prior art and on its face.

Federal Circuit Holdings:

• Reverses summary judgment with regard to invalidity based on anticipation and obviousness because genuine issues of material fact exist.
• Because invalidity by anticipation requires that the four corners of a single, prior art document describe every element of the claimed invention, the district court had to consider whether the prior art references disclosed the Xerox patent's use of stroke direction in distinguishing symbols, even though other limitations of the Xerox patent had clearly been disclosed in the prior art. The conclusion with regard to whether stroke direction was disclosed by the prior art would effect the analysis of obviousness.
• Reverses summary judgment with regard to invalidity based on indefiniteness, because the disputed claims were not insolubly ambiguous. While the descriptions in the Xerox patent of "sloppy space" were not rigorously precise, they provided adequate guidance as to the types of symbols that were separated from each other, given the difficulty of articulating a standard for the concept.