Apple’s Major Products Do Not Infringe PatentsAugust 16, 2023

On August 14, 2023, in One-E-Way, Inc. v. Apple Inc., the Court of Appeals for the Federal Circuit (“Federal Circuit”), in a nonprecedential opinion, affirmed a decision by the Central District of California holding that several popular products sold by tech giant Apple do not infringe U.S. Patent Nos. 10,129,627 (“the ‘627 patent”) or 10,468,047 (“the ‘047 patent”).

In 2020, One-E-Way, Inc. (“One-E-Way”) filed suit against Apple Inc. (“Apple”) in the Central District of California alleging that several popular Apple products, including Apple’s AirPods and particular headphones in the Beats product line, infringe both the ‘627 patent and the ‘047 patent which are both owned by One-E-Way. The ‘627 and ‘047 patents are related to “a wireless digital audio system for coded digital transmission of an audio signal from any audio player with an analog headphone jack to a receiver headphone located away from the audio player.” A representative patent claim from the asserted patents includes a “unique user code” that is used to pair a receiver and a transmitter. The interpretation of the term “unique user code” in the claims of the asserted patents was pivotal to the district court’s holding that Apple’s products do not infringe the patents.

At the district court level, the two parties agreed that the term “unique user code” means “fixed code (bit sequence) specifically associated with one user of a device(s).” Apple argued that its accused products do not meet the “unique user code” limitation of the claims because its products contain codes associated with devices rather than users. One-E-Way countered by arguing that the “unique user code” is “associated with a user through the operation of the device,” and, therefore, Apple’s accused products infringe their patents.

On appeal, the Federal Circuit agreed with the district court that the claim term “unique user code” refers to “a code associated with the user of a device rather than the device itself.” The Federal Circuit based its interpretation of the “unique user code” term on the specifications of the patents as well as relevant prosecution history of a related patent application. The Federal Circuit noted that the patents consistently reference “user” and “device” as separate entities and that the term “unique user code” is consistently associated with a “user.” Additionally, during prosecution of a parent application to the patents the applicant distinguished user codes and device codes. Therefore, the Federal Circuit affirmed the district court’s finding of noninfringement.

Thus, Apple has avoided a finding that several of its major products, including AirPods and headphones in the Beats product line, infringe the ‘627 and ‘047 patents.

Joseph M. Hallman is a Patent Attorney in the Mechanical and Electrical Patent Practice Group at McKee, Voorhees & Sease, PLC. For additional information please visit www.ipmvs.com or contact Joseph directly via email at joseph.hallman@ipmvs.com.