Amazon.Com, Inc. v. Barnesandnoble.Com, Inc.

239 F.3d. 1343 (2001)

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Nature of the Case

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Facts

The '411 patent was issued on September 28, 1999, and is assigned to P. On October 21, 1999, P brought suit against D alleging infringement of the patent and seeking a preliminary injunction. The patent addresses a method and system for 'single action' ordering of items in a client/server environment such as the Internet. The '411 patent describes a method and system in which a consumer can complete a purchase order for an item via an electronic network using only a 'single action,' such as the click of a computer mouse button on the client computer system. An electronic commerce purchaser using the shopping cart model is required to perform several actions before achieving the ultimate goal of the placed order. The '411 patent provides for single-action ordering and reduces the amount of sensitive information that is transmitted between a client system and a server system. The term 'single action' is not defined by the patent specification. The term 'single action' appears to refer to one action (such as clicking a mouse button) that a user takes to purchase an item once the following information is displayed to the user: (1) a description of the item; and (2) a description of the single action the user must take to complete a purchase order for that item. D's system, called 'Express Lane,' also takes previously entered billing and shipping information for the customer and on a displayed 'product page' the customer can take a single action to complete a purchase for the product. The district court concluded that P had made a showing of likelihood of success on its allegation of patent infringement. The district court reviewed the prior art references upon which D's validity challenge rested. The district court concluded that none of the prior art references anticipated the claims of the '411 patent under §102 or rendered the claimed invention obvious under §103. The injunction issued and D appealed.