Rovi Guides, Inc. v. Videotron Ltd.
ROVI GUIDES, INC.
Law Firm / Organization
Lenczner Slaght LLP
VIDEOTRON LTD.

The case Rovi Guides, Inc. v. Videotron Ltd. involves a dispute over patent infringement concerning interactive television program guide (IPG) technology. Here is a concise summary of the key points from the document:

  • Parties Involved:

    • Rovi Guides, Inc. (Appellant): Claimed Videotron infringed its IPG patents.
    • Videotron Ltd. (Respondent): Successfully counterclaimed for invalidity and non-infringement of Rovi’s patents.
  • Patents in Question:

    • Four patents related to IPG technology, particularly for television program listings and recorded content navigation, were involved: Canadian Patents Nos. 2,337,061, 2,339,629, 2,336,870 (870 Patent), and 2,730,344 (344 Patent).
    • The 870 Patent covered systems allowing users to record and play back TV programs across different user equipment.
    • The 344 Patent related to IPG functionality across multiple devices within a household.
  • Federal Court Decision:

    • The court found that Rovi’s patent claims were either anticipated or obvious based on prior art and the common general knowledge of a skilled person.
    • Rovi’s claims for infringement were dismissed, and Videotron’s counterclaims for patent invalidity and non-infringement were upheld.
  • Appeal:

    • Rovi appealed the decision, contesting the court's analysis on obviousness and non-infringement for the 870 and 344 patents.
    • The court of appeal found no reviewable error in the obviousness analysis but corrected some points regarding the remedy (accounting of profits).
  • Outcome:

    • The appeal was dismissed, with Rovi not entitled to an accounting of profits but only to a reasonable royalty had the claims been valid. Costs were awarded against Rovi: No amount specified.
Federal Court of Appeal
A-186-22
Intellectual property
Respondent
12 September 2022