DDR Holdings, LLC v. Hotels.com, L.P.
United States Court of Appeals for the Federal Circuit
773 F.3d 1245, 113 U.S.P.Q.2d 1097 (2014)
- Written by Sean Carroll, JD
Facts
DDR Holdings, LLC (plaintiff) owned two patents for systems of creating composite webpages that combined the logos and graphics of the host company with information from third-party merchants. Using this system, if a user clicked on a third-party merchant’s advertisement on a host company’s website, the user was taken to an outsourced hybrid webpage with the look and feel of the host’s website but with product information from the third party. This practice retained webpage visitors for the host company by allowing the visitors to purchase products from the third party without going to the third party’s website. DDR brought a patent infringement suit against National Leisure Group, Inc. (defendant) in the United States District Court for the Eastern District of Texas. The jury found in favor of DDR. NLG appealed, arguing that the subject matter of the patents were not patentable and that one of the patent claims was invalid because it was anticipated. NLG argued that the claim was anticipated due to a Secure Sales System (SSS) implemented by Digital River, Inc. prior to DDR’s patent application. Digital River’s SSS created a composite website for users when they clicked “buy” on the host’s website. DDR argued that the SSS did not disclose the look and feel limitation in DDR’s claim.
Rule of Law
Issue
Holding and Reasoning (Chen, J.)
Dissent (Mayer, J.)
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