In Lincoln Nat'l Life Ins., Co. v. Transamerica Life Ins., Co., No. 09-1403, the Federal Circuit faced a challenge to the district court's denial of defendants' motion for summary judgment as a matter of law that it does not infringe the claims at issue of the '201 patent in a suit for patent infringement, related to computerized methods for administering variable annuity plans.
As stated in the decision: "[S]tep (e) recites making guaranteed payment regardless of the account value. Under the court's interpretation, Lincoln was required to prove that Transamerica's computerized systemt is configured to make payments regardless of account value, even if the account value is exhausted before all payments have been made...Because Transamerica's computerized system does not make a payment if an account is exhausted, the systemt does not make a guaranteed payment regardless of the account value. Therefore, Lincoln failed to prove that Transamerica performs step (e)."
Thus, in reversing the judgment, the court held that the district court erred in denying defendants' motion for JMOL of noninfringement as the evidence on the record does not support jury's verdict of infringement. Furthermore, because defendant does not infringe, its argument that the district court abused its discretion by refusing to grant it leave to amend its complaint to assert a claim for invalidity under 35 U.S.C. section 101 need not be addressed.