Massachusetts Inst. of Tech. v. Abacus Software

Massachusetts Institute of Technology (“MIT”) and Electronics for Imaging, Inc. (“EFI”) appeal from the stipulated final judgment of noninfringement of the United States District Court for the Eastern District of Texas. MIT and EFI urge that the district court’s claim construction (on which the stipulated judgment of non-infringement was based) was erroneous. Appellants also urge that the district court’s order granting Microsoft’s motion to exclude Windows as an infringing product was erroneous. We vacate the grant of summary judgment and remand for further proceedings because we hold that the district court erred in its construction of “aesthetic correction circuitry,” and erred in excluding Windows as an infringing product. We decline to address claim construction issues not implicated by the judgment. We dismiss the cross-appeals since the cross-appeals, if successful, would not expand the scope of the judgment. We decline to reach the question whether the district court properly denied the parties’ motions for summary judgment on the marking statute issues since the district court has not finally decided whether the marking statute bars the claims. We dismiss as moot the appeals insofar as they arise from orders that were granted in favor of Fry’s Electronics, Inc. (“Fry’s”) and Arcsoft, Inc. (“Arcsoft”) because both those parties have been voluntarily dismissed from this action.

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