The U.S. Appeals Court, Federal Circuit, vacated a lower court su...

TV programming with Web pages by using the video blanking interval of an analog video signal to send a uniform resource locator (URL) specifying the location of online content, the appeals court said. ACTV sued Disney and the others for patent infringement in U.S. Dist. Court, N.Y. After that court construed the term “Internet address” in ACTV’s patents to mean “a particular host on the Internet, specified by a uniform [URL] that is unique to that host,” and “Internet information segments” to mean “parts into which information on the Internet is commonly divided, such as a Web page,” Disney sought summary judgment, saying its ETV system transmitted only file names, not absolute URLs. Moreover, it argued, because absolute URLs weren’t transmitted, its ETV system didn’t receive, decode or interpret URLs as defined by the trial court. The lower court held Disney’s ETV system didn’t perform the identical functions of ACTV’s patents and thus didn’t directly infringe. The Federal Circuit disagreed, saying: (1) Despite ACTV’s failure to explicitly define URL, the patents didn’t indicate a clear intent to limit the definition to absolute URLs (addresses consisting of a protocol type such as “http://” and a resource location such as “www.fedcir.gov") as opposed to both absolute and “relative” URLS -- that is, those made up of less than a protocol type and a resource locator. (2) Both parties’ reliance on Requests for Comment (RFCs) from the World Wide Web Consortium (W3C) was misplaced because such documents, far from being authoritative, unbiased sources relating to the meaning of URL, were simply working papers meant to “assign language to facilitate further discussion.” (3) The trial court erred in construing URL to encompass only absolute URLs. Instead, the appellate court said, in ACT’s patents, URL meant a reference identifying the location of information segments such as audio clips, Web pages and images. (4) The file names transmitted by Disney’s ETV system fell within the scope of the term URL. The Federal Circuit ordered the lower court to consider ACTV’s claims of both literal infringement and infringement under the doctrine of equivalents.