Technology Patents, LLC v. T-Mobile (UK) Ltd.

Doctrine of Equivalents will not broaden claims beyond their explicit terms.

Opinion (Bryson): Technology Patents, LLC (“TP”) appealed summary judgment in favor of T-Mobile (“TM”). The lower court found that the TM feature did not infringe TP’s global paging system patent, which permitted users to create a list of preferred countries to expedite their phone’s message delivery process. The TP patent used user input to establish a predetermined priority country list that a global communication system (“CS”) then used to cycle through for message delivery, instead of making a user’s phone consistently cycling through and updating the CS via an inefficient roaming protocol. Under TP, once the CS contacted the user’s CS identification number, the CS cycled through the predetermined country list until the message was delivered. The accused infringing TM feature established contact with the nearest service tower regardless of country of origin to create list and permitted the user to select their carrier. TP asserted that by permitting users to select carriers from different countries of origin, TM infringed TP’s patent because the act established a user-defined list. The Court found that TM only permitted the user to select a carrier and not a country, which is the dispositive term in the claimed patent. Furthermore, the system did not meet the required predetermined order because the user could not create the list. Finally, the Court found that the TM feature did not determine if the selected carrier’s country was designated as the primary contact protocol in the CS. Thus, judgment was AFFIRMED.