General Electric Co. v. Nintendo Co., Ltd.

General Electric Co. (GE) (plaintiff) owned patents for television control circuitry. The ’899 patent was written in means-plus-function language and described a switch that allowed television users to change between signals from a television antenna and alternate sources. The switch operated by disrupting the flow of broadcast signals from the antenna to the television receiver and directing signals from the alternate source. If the switch was open, the antenna signal path was blocked, and if the switch was closed, the antenna signal could flow. The ’659 patent described a signal generator used in video source equipment. Televisions displayed pictures as numbers of pixels that were transmitted to a receiver along with timing information and horizontal and vertical positioning counters. The generator created drive signals with specialized vertical counters. The ’125 patent described a method for displaying computer-generated information on a display screen. Standard computers used a central processing unit (CPU) to transfer image data. The ’125 patent utilized a direct-memory-access (DMA) circuit, allowing the computer to transfer image data without a CPU. The invention used a bit-mapping device to display images on screen one bit at a time. During the prosecution, bit-mapping was distinguished from a character-generation system that created images using groupings of bits rather than individual units. Nintendo Co., Ltd. (defendant) produced several video-game systems. The systems allowed users to select signal sources by bypassing the television antenna-signal path, creating an alternative path of lower resistance that directed the antenna signal away from the television and into the ground. The systems also utilized a signal generator to create drive signals with no specialized vertical counters. Additionally, the systems displayed images without a CPU or a DMA circuit specifically, instead using a separate piece of hardware to transfer the data and make DMA requests. The systems utilized character generation to display images. GE sued Nintendo for infringement, but the district court granted summary judgment for Nintendo. GE appealed.