Fed. Cir. Affirms Hulu Win Against Database Patent
Written July 6, 2020
The Federal Circuit on July 2, 2020, affirmed Hulu LLC‘s successful challenge to the validity of a database management patent at the Patent Trial and Appeal Board (PTAB). Sound View Innovations LLC v. Hulu LLC, Fed. Cir., No. 19-1865, unpublished 7/2/20.
Sound View Innovations LLC’s patent covers systems for optimizing a database by reclaiming memory space that is no longer used. Hulu and Unified Patents LLC challenged parts of the patent at the PTAB, arguing the invention had already been disclosed in a textbook.
Sound View argued that the board erred in finding the textbook disclosed the patent’s monitoring function. But the Federal Circuit agreed with the board that the textbook’s disclosure of determining when a data manager runs out of space met the “monitoring” limitation. The court also rejected Sound View’s validity argument that a person of ordinary skill wouldn’t have had a reasonable expectation of success in creating the invention based on the textbook alone.