IP Law Daily, PATENT—Fed. Cir.: Multimedia patent owner secures partial revival of patent claims against Amazon on appeal, (Jul 6, 2026)

By Saurabh Kashyap, B.A., M.A., LL.B., LL.M.

One patent received a fresh indefiniteness analysis under intervening precedent, while the invalidity of a related patent remained supported by substantial evidence.

The U.S. Court of Appeals for the Federal Circuit vacated a district court ruling invalidating the asserted claims of a patent directed to multimedia navigation technology and remanded for further proceedings, holding that the district court's means-plus-function analysis required reconsideration in light of intervening precedent. However, the court affirmed a jury verdict invalidating a related patent claim as anticipated, concluding that substantial evidence supported the finding that a prior-art software program disclosed every limitation of the asserted claim (TrackTime, LLC v. Amazon.com Services LLC, No. 24-1102 (Fed. Cir. Jul. 2, 2026)).

Background. The plaintiff/appellant, TrackTime, LLC, develops and owns patents relating to multimedia navigation technology. The defendants/appellees, Amazon.com Services LLC and Audible, Inc., provide e-commerce, digital content, and audiobook services.

The dispute involved U.S. Patent Nos. 8,856,638 (the ’638 patent) and 8,862,978 (the ’978 patent). The patents share a common specification and generally relate to methods and systems that allow users of mobile computing devices to navigate multimedia files using time-correlated transcripts. The technology enables users to jump to portions of audio or video by selecting corresponding text in a synchronized transcript, to annotate the transcript, and share those annotations with others.

TrackTime sued Amazon in 2018, alleging infringement of the '638 and '978 patents. During claim-construction proceedings, Amazon argued that two "executable program code" limitations in the asserted claims of the ’978 patent were governed by 35 U.S.C. § 112(f) and were therefore indefinite because the specification failed to disclose corresponding structure. Separately, Amazon asserted that claim 9 of the ’638 patent was anticipated by LiveNote, a prior-art transcript management program. The district court agreed with Amazon on the ’978 patent, while a jury later found claim 9 of the ’638 patent invalid for anticipation and not infringed. After the district court denied TrackTime's post-trial motions, TrackTime appealed.

Means plus function. The Federal Circuit concluded that the district court's indefiniteness ruling regarding the ’978 patent required further analysis.

The district court had treated the limitations reciting "executable program code configured to facilitate annotation" and executable program code configured to synchronously play multimedia as means-plus-function limitations under Section 112(f). It then held the claims indefinite because the specification failed to disclose adequate corresponding structure.

The Federal Circuit held that the district court's analysis predated its decision in Dyfan, LLC v. Target Corp., 28 F.4th 1360 (Fed. Cir. 2022), which clarified how courts should determine whether software-related claim language invokes Section 112(f). Under Dyfan, courts must evaluate the disputed limitation as a whole and determine whether the claim language, read in context, would convey sufficient structure to a person of ordinary skill in the art.

The appellate court observed that the district court focused largely on whether the phrase "executable program code," standing alone, conveyed structure, without fully analyzing whether the claimed skilled artisans would have understood the annotation and synchronous-play operations themselves as referring to known software structures. It also noted that the parties' expert evidence had not been directed to the proper inquiry under the subsequently decided Dyfan framework.

Accordingly, the court vacated the indefiniteness ruling and remanded the case to the district court to determine anew whether the disputed limitations invoke Section 112(f). In doing so, it instructed the district court to consider both intrinsic and, if necessary, extrinsic evidence regarding how persons skilled in the art would have understood the claim language.

Anticipation. TrackTime argued that LiveNote failed to disclose several limitations of claim 9, including a mobile computing device, a touch-sensitive input interface, and the performance of a data lookup using a synchronization index. The appellate court rejected those arguments.

The court found substantial evidence supporting the jury's verdict of anticipation. LiveNote's user guide expressly described operation on a tablet PC, which the asserted patent itself identified as a type of mobile computing device. The guide also disclosed the use of a tablet pen, and Amazon's expert testified that a person of ordinary skill would understand that the software operates on touchscreen devices using either a pen or a finger.

The court further concluded that TrackTime's arguments reflected a competing interpretation of the evidence rather than a lack of evidentiary support. Because the jury was entitled to credit Amazon's expert testimony over that of TrackTime's expert, the district court properly denied judgment as a matter of law. The Federal Circuit therefore affirmed the jury's finding that LiveNote anticipated claim 9 of the '638 patent.

New trial. TrackTime alternatively sought a new trial, arguing that the anticipation verdict was against the clear weight of the evidence. The Federal Circuit rejected that contention. Citing Leonard v. Stemtech International Inc., 834 F.3d 376 (3d Cir. 2016), the court explained that a new trial is warranted only when a verdict "cries out to be overturned" or "shocks the conscience." Here, the LiveNote documentation and Amazon's expert testimony provided substantial evidentiary support for the jury's verdict. At most, the case presented a routine conflict between competing experts, which the jury was entitled to resolve. The district court, therefore, did not abuse its discretion in denying a new trial.

Because the anticipation finding independently sustained the judgment of invalidity, the Federal Circuit declined to address TrackTime's remaining challenges relating to infringement, obviousness, and patent eligibility. The court affirmed the judgment regarding the ’638 patent, vacated the indefiniteness ruling concerning the ’978 patent, and remanded for further proceedings.

The Case is No. 24-1102.

Judge: Taranto, R.

Attorneys: Robert Greenspoon (Dunlap Bennett & Ludwig PLLC) for TrackTime, LLC. J. David Hadden (Fenwick & West LLP) for Amazon.com Services LLC and Audible, Inc.

Companies: TrackTime, LLC; Amazon.com Services LLC; Audible, Inc.

Cases: Patent FedCirNews TechnologyInternet