Orange Electronic Co. Ltd. v. Autel Intelligent Technology Corp., Ltd.

N OTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
ORANGE ELECTRONIC CO. LTD.,
Plaintiff-Appellant
v.
AUTEL INTELLIGENT TECHNOLOGY CORP.,
LTD.,
Defendant-Cross-Appellant
______________________
2024-1876, 2024-1885
______________________
Appeals from the United States District Court for the
Eastern District of Texas in No. 2:21-cv-00240-JRG,
Judge J. Rodney Gilstrap.
______________________
Decided: January 23, 2026
______________________
J OHN F. RABENA, Sughrue Mion, PLLC, Washington,
DC, argued for plaintiff-appellant. Also represented by
WILLIAM MANDIR.
N ICOLE A. SAHARSKY , Mayer Brown, LLP, Washing-
ton, DC, argued for defendant-cross-appellant. Also
represented by CLARK BAKEWELL , J AMES A. F USSELL , III,
G ARY HNATH , BRYAN N ESE , MINH N GUYEN-D ANG; HAO
T AN, SHEN WANG, Arch & Lake LLP, Chicago, IL.
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ORANGE ELECTRONIC CO . LTD. v.
AUTEL INTELLIGENT TECHNOLOGY CORP ., LTD.
2
______________________
Before D YK, T ARANTO, and CUNNINGHAM , Circuit Judges.
D YK, Circuit Judge.
Orange Electronic Co. Ltd. (“Orange”) sued Autel In-
telligent Technology Corp., Ltd. (“Autel”) in the Eastern
District of Texas alleging infringement of claims 26 and
27 of U.S. Patent No. 8,031,064 (“’064 patent”). The jury
found that both claims were not invalid as obvious under
35 U.S.C. § 103 and not directed to patent ineligible
subject matter under 35 U.S.C. § 101 and that Autel
directly infringed the claims. After the trial, Autel moved
for judgment as a matter of law (“JMOL”) on obviousness,
patent ineligible subject matter, and noninfringement.
The district court denied JMOL with respect to obvious-
ness and patent ineligible subject matter. However, the
district court granted JMOL as to noninfringement,
concluding that the evidence established that Autel did
not sell, offer to sell, or import infringing goods into the
United States. Orange appeals the district court’s grant
of JMOL as to noninfringement, and Autel cross-appeals
the district court’s denial of JMOL as to 35 U.S.C. §§ 101
and 103. We reverse as to obviousness and accordingly do
not reach the issue of patent eligible subject matter under
section 101 or the issue of infringement.
BACKGROUND
The ’064 patent is directed to “an identification re-
writable tire pressure detecting apparatus.” ’064 patent,
col. 1 ll. 10–11. The patent describes a system where a
“new tire pressure detector can . . . easily replace[] a
fail[ed] tire pressure detector by cop[y]ing the identifica-
tion of the fail[ed] tire pressure detector.” Id., col. 1 l. 65–
col. 2 l. 2.
Claim 26 of the ’064 patent, which is representative of
the asserted claims, recites (with the relevant claim
language highlighted):
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ORANGE ELECTRONIC CO . LTD. v.
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A tire pressure detecting system, comprising:
an identification rewritable tire pressure
detector used for being installed in a vehi-
cle, the identification rewritable tire pres-
sure detector comprising:
a micro-processing module having
a rewritable memory unit to rec-
ord an identification;
a sensing module electrically con-
nected to the micro-processing
module and having a pressure-
detecting unit to detect a tire pres-
sure and send a detection result to
the micro-processing module;
a transmitting module controlled
by the micro-processing module to
transmit a radio frequency (RF)
signal, wherein the RF signal
comprises the detection result and
the identification of the identifica-
tion rewritable tire pressure detec-
tor;
a power module electronically
connected to the micro-processing
module to supply power to the
identification rewriteable tire
pressure detector; and
an interface arranged to receive an exter-
nal signal and send the external signal to
the micro-processing module, wherein the
external signal comprises an external
identification to be written into the re-
writeable memory unit or to be used to
overwrite a preset identification in the
rewriteable memory unit; and
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ORANGE ELECTRONIC CO . LTD. v.
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a portable setting apparatus arranged to
communicate with the identification re-
writeable tire pressure detector, compris-
ing;
a control module;
an input module connected to the
control module to enable an opera-
tor to manually input an identifi-
cation to be written into the
identification rewriteable tire
pressure detector;
a receiving module connected to
the control module to receive the
RF signal from the identification
rewriteable tire pressure detector
or a tire pressure detector and to
send the RF signal to the control
module;
a setting output module controlled
by the control module to send the
external signal to the interface of
the identification rewriteable tire
pressure detector, wherein the ex-
ternal signal is generated by the
control module and comprises the
identification that is provided by
the input module or provided by
the RF signal received from the
receiving module; and
a power source connected to the
control module to supply power to
the setting apparatus;
wherein the portable setting apparatus is
not equipped in the vehicle and is portable
relative to the vehicle, and is configured
to:
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obtain an update identification to
be written into a new identifica-
tion rewriteable tire pressure de-
tector either by (1) receiving the
RF signal from an old tire pres-
sure detector by the receiving
module, retrieving an old identifi-
cation of the old tire pressure de-
tector from the RF signal, and
using the old identification as the
update identification, or by (2) re-
ceiving a manual input of the
identification from the input mod-
ule, and using the identification as
the update identification, wherein
the old tire pressure detector
stores only the old identification;
store the update identification in
the setting apparatus; and
generate the external signal com-
prising the update identification
as the external identification, and
send the external signal to the
new identification rewriteable tire
pressure detector such that the
new identification rewriteable tire
pressure detector records the up-
date identification in the rewrita-
ble memory unit or overwrites the
preset identification in the rewrit-
able memory unit by the update
identification, wherein the exter-
nal identification is from the old
tire pressure detector, and the ex-
ternal signal is a low frequency
(LF) signal.
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ORANGE ELECTRONIC CO . LTD. v.
AUTEL INTELLIGENT TECHNOLOGY CORP ., LTD.
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’064 patent, claim 26 (emphases added).
Autel manufactures tire pressure monitoring system
(“TPMS”) setting mechanisms. Autel’s subsidiary, Autel
U.S., sells Autel’s products to customers in the United
States. On June 30, 2021, Orange sued Autel for in-
fringement of the ’064 patent. Autel brought a counter-
claim of invalidity under sections 101, 102, 103, and/or
112.
From June 5–8, 2023, the district court held a jury
trial. The jury found that Autel infringed the asserted
claims (claims 26 and 27) and that neither of those claims
was invalid under 35 U.S.C. §§ 101 or 103. The jury
awarded Orange $6,616,397 in damages.
In a posttrial JMOL motion, Autel argued that JMOL
should be granted because claims 26 and 27 are invalid as
obvious under section 103 based on the combination of
U.S. Patent Application Publication No. 2007/0055411
(“Nihei”) in view of U.S. Patent Application Publication
No. 2006/0208864 (“Nantz”). It also argued that the
JMOL should be granted because the asserted claims are
directed to patent ineligible subject matter under sec-
tion 101. The district court denied Autel’s motion as to
obviousness, concluding that “substantial evidence sup-
ports the jury’s verdict that Autel has not shown the
Asserted Claims to be obvious by clear and convincing
evidence.” J.A. 55.1 And while the district court conclud-
ed that the asserted claims were directed to an abstract
idea, it denied JMOL as to section 101 under step 2 of the
Supreme Court’s framework in Alice Corp. v. CLS Bank
Int’l, 573 U.S. 208 (2014). The district court did, however,
grant Autel’s motion for JMOL of noninfringement, find-
1 Citations to the J.A. refer to the Joint Appendix
filed by the parties at Dkt. No. 26.
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ORANGE ELECTRONIC CO . LTD. v.
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ing no evidence of sales, offers for sale, or importation in
the United States.
Orange appeals the district court’s grant of JMOL of
noninfringement and Autel cross-appeals the district
court’s denial of JMOL as to invalidity under 35 U.S.C.
§§ 101 or 103. We have jurisdiction under 28 U.S.C.
§ 1295(a)(1).
D ISCUSSION
We need only consider the district court’s denial of
JMOL as to obviousness. “A patent for a claimed inven-
tion may not be obtained . . . if the differences between
the claimed invention and the prior art are such that the
claimed invention as a whole would have been obvious
before the effective filing date of the claimed invention to
a person having ordinary skill in the art.” 35 U.S.C.
§ 103. “We review the jury’s conclusions on obviousness, a
question of law, without deference, and the underlying
findings of fact, whether explicit or implicit within the
verdict, for substantial evidence.” Bos. Sci. Scimed, Inc.
v. Cordis Corp., 554 F.3d 982, 990 (Fed. Cir. 2009) (quot-
ing Johns Hopkins Univ. v. Datascope Corp., 543 F.3d
1342, 1345 (Fed. Cir. 2008)).
The claims describe a “tire pressure detecting sys-
tem.” See ’064 patent, claim 26. The invention of the ’064
patent is “an identification rewritable tire pressure detec-
tor,” that can replace a broken tire pressure detector. Id.
To do this, the claims describe, a “portable setting appa-
ratus” that rewrites the old tire pressure detector’s identi-
fication onto the new tire pressure detector. Id.
Autel argues that the combination of two pieces of
prior art, Nihei and Nantz, renders the asserted claims
obvious. Nihei is directed to “a wheel information-
acquiring system for transmitting, by radio, wheel infor-
mation to a vehicle body . . . for example, inner pressure
data and temperature data of a tire.” J.A. 3751, ¶ 1.
Nihei’s system includes a “setting device . . . connected to
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the PC [personal computer]” that “upon manual inputting
of an ID to be set for the transmitter” can transmit and
receive signals containing information from another
communication device. J.A. 3755, ¶ 63. Nantz “provides
an improved method and improved system for tire pres-
sure monitoring (TPM) sensor testing and diagnosis.”
J.A. 3742, ¶ 12. Nantz discloses one embodiment where,
when a “TPM sensor 104 is damaged or functioning
incorrectly, immobilizer 102 may read the ID [identifica-
tion] of the damaged TPM sensor and transmit . . . the ID
of the damaged sensor to a replacement TPM sensor 104.”
J.A. 3743, ¶ 30.
Autel presented testimony that the Nihei/Nantz com-
bination satisfies all the limitations of the asserted
claims, that a person of skill in the art would be motivat-
ed to combine Nihei and Nantz, and that secondary
considerations do not support a conclusion of nonobvious-
ness. However, the district court denied Autel’s motion
for JMOL as to obviousness because it found substantial
evidence that “Nihei and Nantz fail to teach or suggest
the Asserted Claims’ ‘portable setting apparatus’ limita-
tions” and accordingly “[did] not reach the other obvious-
ness-related issues raised by the [p]arties.” J.A. 55. On
appeal, the parties do not dispute that Autel’s proposed
combination meets most of the claim limitations. Howev-
er, Orange argues that the district court was correct as to
the “portable setting apparatus” limitation and that the
combination in other respects does not render the claims
obvious.
First, Orange argues that the jury heard substantial
evidence to conclude that the prior art combination of
Nihei/Nantz does not disclose a “portable setting appa-
ratus.” A predicate question is what in the Nihei/Nantz
combination constitutes the setting apparatus. Autel
argues that Nihei’s setting device and PC together dis-
close the claimed “portable setting apparatus.” Orange
argues that there is substantial evidence to support a
finding that the setting device alone in Nihei is the
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claimed setting apparatus. But there is no such testimo-
ny in the record to support Orange’s argument. The only
testimony as to what constitutes the setting apparatus
comes from Autel’s expert, Dr. Souri, who testified that
the setting device and PC “form the setting apparatus”
because “the PC is the brain. . . . It’s what performs the
control function” required by the claims. J.A. 2917; see
’064 patent, claim 26. We agree with Autel that the
record can only support the conclusion that the setting
apparatus in the Nihei/Nantz combination constitutes
both the setting device and the PC.
Given that the setting device and the PC together
form the claimed setting apparatus in the Nihei/Nantz
combination, Autel argues that the “portable setting
apparatus” limitation is satisfied. Orange argues that a
reasonable jury could conclude the setting apparatus is
not portable because it must be “h[e]ld” so a technician
can “go to the wheel.”. Oral Argument 30:16–26. Or-
ange’s expert witness, Mr. McAlexander, testified that the
setting device in Nihei “is not a portable device” because it
is “tethered to a personal computer.” J.A. 3154. But the
claims only require that the setting apparatus be portable
“relative to the vehicle,” not that it be handheld.
’064 patent, claim 26. Mr. McAlexander offered no testi-
mony explaining why Nihei’s setting device and PC are
not portable relative to the vehicle. Without contradiction,
Dr. Souri testified Nihei’s setting device and PC are
“portable to the vehicle so that you’re able to move around
and program the sensors in the wheels.” J.A. 2918.
Mr. McAlexander, indeed, admitted that Nihei’s setting
device and PC “move independently from Nihei’s vehicle.”
J.A. 3167–68. We accordingly do not find substantial
evidence to support the jury’s verdict of nonobviousness as
to a portable setting apparatus.
Second, Orange argues that Nihei does not disclose a
setting apparatus “configured to . . . receiv[e] a manual
input of the identification” as required by the asserted
claims. ’064 patent, claim 26. While Nihei’s setting
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device does not receive manual input, Nihei’s setting
apparatus including a PC does. Given that the only
configuration of the setting apparatus supported by
substantial evidence includes the PC, no reasonable jury
could conclude that the prior art did not disclose the
manual input limitation. Indeed, as Mr. McAlexander
stated, “manual input [is] available . . . at the PC.”
J.A. 3154.
Third, Orange argues that Nihei and Nantz do not
render the asserted claims obvious because the Ni-
hei/Nantz combination requires that the operator access
and update the sensor ID on the vehicle’s computer.
Mr. McAlexander testified that “the only way this system
[the combination] works is that you have to change the
identification on the sensor and the controller in the
vehicle, and that is not what the ’064 patent teaches.”
J.A. 3153–54. The claims do not preclude a device that
uses a computer. See ’064 patent, claim 26. As counsel
for Orange conceded at oral argument, the asserted
claims say nothing about precluding the use of the vehi-
cle’s computer. Oral Argument at 27:45–28:11 (“There’s
not an express recitation that you don’t have to communi-
cate with the car.”)
Fourth, Orange argues that the Nihei/Nantz combina-
tion does not teach a tire pressure detection sensor that
transmits RF signals to the setting apparatus as required
by the claims. However, this is exactly what Nihei teach-
es. As Dr. Souri explained, “Nihei discloses the setting
device that can receive the RF signal,” which means the
tire pressure detection sensor transmits an RF signal to
the setting apparatus. J.A. 2929. Orange’s theory ap-
pears to be that Nantz teaches away from a sensor that
transmits RF signals because it discloses a sensor with a
two-way LF channel. But teaching an LF embodiment
does not suggest that an RF embodiment is not desirable.
In other words, there is no teaching away.
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Finally, Orange argues that Nantz teaches storing “a
bank of TPM sensor IDs,” which are used to assign a new
ID to the replacement tire pressure detection sensor, and
the asserted claims require using the old identification.
J.A. 3743, ¶ 30. But the bank of sensor IDs is explicitly
described in Nantz as “one embodiment” and an “alterna-
tive embodiment” “read[s] the ID of the damaged TPM
sensor and transmit[s] an LF signal containing the ID of
the damaged sensor to a replacement TPM sensor.” Id.
The undisputed evidence shows that the Nihei/Nantz
combination discloses using the old sensor ID.
Orange does not identify any other defects in the
combination that could render the asserted claims not
obvious. In one sentence in its response brief to Autel’s
cross-appeal, Orange suggests that secondary considera-
tions support the district court’s denial of JMOL, but this
argument is undeveloped. The same is true for Orange’s
argument concerning motivation to combine. We conclude
no reasonable jury could have found the claims nonobvi-
ous in view of Nihei and Nantz and that substantial
evidence does not support the jury’s verdict of nonobvi-
ousness. We accordingly reverse the district court’s grant
of JMOL as to obviousness and need not reach either the
issue of patent ineligible subject matter under section 101
or the issue of infringement.
REVERSED
COSTS
Costs to Autel.
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