Dow Jones & Co., Inc. v. Ablaise Ltd.
Court of Appeals for the Federal Circuit · 2010-05-28 · cited 74×
This case involved Dow Jones challenging the validity of two patents owned by Ablaise (the '737 and '530 patents) that described methods for dynamically generating customized web pages based on user information. The district court granted summary judgment invalidating the '737 patent claims as obvious under 35 U.S.C. § 103 and the '530 patent claims as anticipated under 35 U.S.C. § 102, while also denying Ablaise's motion to dismiss the '530 claim for lack of subject matter jurisdiction after Ablaise offered a covenant not to sue. On appeal, the Federal Circuit affirmed the obviousness ruling for the '737 patent, finding the claims obvious in light of prior art such as the Bobo reference combined with general knowledge in the field at the time. The court reversed the jurisdiction ruling, holding that the covenant not to sue eliminated any case or controversy over the '530 patent and thus deprived the district court of authority to rule on its validity.