Justia Intellectual Property Opinion Summaries

Two companies that manufacture activated carbon honeycombs, used in automotive emission control systems, became embroiled in a legal dispute. One company holds a patent covering certain dual-stage fuel vapor canister systems, but not honeycombs used in air-intake systems. The other company began marketing a competing honeycomb product, prompting a patent infringement lawsuit. In response, the defendant challenged the validity of the patent, argued non-infringement, and asserted counterclaims alleging antitrust violations—specifically, that the patent holder unlawfully tied licenses for the patent to the purchase of its unpatented honeycomb products.The United States District Court for the District of Delaware first granted summary judgment that the patent was invalid due to prior invention. It then denied both parties’ motions for summary judgment on the antitrust and tortious interference counterclaims, finding a factual dispute about whether the honeycomb products had substantial non-infringing uses. At trial, the jury found the patent holder liable for unlawful tying under federal antitrust law, concluding that it had conditioned patent licenses on customers buying its honeycombs, and awarded significant damages. The district court denied the patent holder’s motions for judgment as a matter of law and for a new trial, confirming the jury’s findings that the honeycombs were staple goods with substantial non-infringing uses and that the conduct was not protected by immunity doctrines.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court’s judgment. The Federal Circuit held that substantial evidence supported the jury’s findings that the honeycomb products had actual and substantial non-infringing uses, making them staple goods and removing the patent holder’s statutory defense against antitrust liability. The court also rejected the argument that the patent holder’s conduct was immunized from antitrust scrutiny, and upheld the damages award, finding no error in the district court’s rulings or the jury’s determinations. View "INGEVITY CORPORATION v. BASF CORPORATION " on Justia Law

GoTV Streaming, LLC owned three related patents that describe a system in which a server receives a content request from a wireless device, tailors the content to that device’s capabilities (such as screen size), and sends the modified content to the device for display. The patents were designed to reduce the burden of developing unique applications for each device type. Instead, the server uses generic templates and custom configurations that are then tailored to the specific device’s needs.The United States District Court for the Central District of California initially dismissed GoTV’s claims for induced infringement, holding that such claims require the defendant’s knowledge of the patents before the lawsuit. The court also denied Netflix’s motion that the patents were ineligible under 35 U.S.C. § 101, finding the claims were not directed to abstract ideas. The court later found all claims of the ’865 patent indefinite and invalid, adopted some of GoTV’s proposed claim constructions, and denied GoTV’s motions to exclude certain Netflix damages evidence. At trial, the jury found Netflix infringed only one patent and awarded GoTV $2.5 million in damages. The district court denied GoTV’s post-trial motions, including for retrial on damages and for prejudgment interest predating the complaint.The United States Court of Appeals for the Federal Circuit reviewed the case. It reversed the district court’s indefiniteness finding for the ’865 patent and adopted GoTV’s claim construction. However, it held that all asserted claims were patent-ineligible under § 101 because they were directed to the abstract idea of using a generic template tailored for a user’s device without reciting an inventive concept. The Federal Circuit reversed the district court’s judgment for GoTV, ordered judgment for Netflix, and vacated the district court’s rulings on inducement and damages evidence. View "GOTV STREAMING, LLC v. NETFLIX, INC. " on Justia Law

Range of Motion Products, LLC owns a design patent for a body massaging apparatus, which is embodied in its product, the Rolflex. Armaid Company Inc. manufactures the Armaid2, an accused product in this suit, as well as an earlier version, the Armaid1, which was covered by a utility patent. RoM alleged that the Armaid2 infringed its design patent. Previously, RoM had filed a similar suit against Armaid in the same court, but that case was dismissed without prejudice following the denial of a preliminary injunction.In the subsequent action, the United States District Court for the District of Maine construed the design patent, carefully distinguishing between functional and ornamental aspects of the claimed design. The court found that many features, notably the shape of the arms and the base, were primarily functional, narrowing the scope of the claimed design. Upon reviewing the evidence, the district court concluded that no reasonable jury could find the design of the Armaid2 substantially similar to the patented design, and granted summary judgment of non-infringement in favor of Armaid.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s claim construction de novo and its grant of summary judgment under the First Circuit’s de novo standard. The Federal Circuit affirmed the district court’s judgment, holding that the district court did not err in identifying the functional versus ornamental aspects of the claimed design, and finding that the designs were plainly dissimilar when considering only the ornamental features. The court further held that, even when comparing the accused and claimed designs alongside prior art, no reasonable jury could find substantial similarity. The judgment of non-infringement was affirmed. View "RANGE OF MOTION PRODUCTS, LLC v. ARMAID COMPANY INC. " on Justia Law

The dispute centered on technology for streaming media over networks, specifically a method described in a now-expired patent for reducing latency and improving stream quality using intermediate “helper servers” to cache and coordinate content distribution. The patent’s method claim at issue involved several steps, including receiving a request for a streaming media object from a client at a helper server, allocating a buffer at the helper server to cache part of the requested object, downloading that portion to the client while concurrently retrieving the remaining portion, and adjusting the transfer rate. The plaintiff alleged that the defendant’s system infringed this method claim by directing third-party edge servers to perform these steps.The United States District Court for the Central District of California previously granted summary judgment of noninfringement in favor of the defendant. The district court found that the accused system did not perform the required steps in the order set out in the claim and that it did not use the kind of “specialized buffer” the patent required. On a prior appeal, the United States Court of Appeals for the Federal Circuit affirmed some claim constructions, vacated the summary judgment, and remanded for further construction of the term “buffer.” On remand, the district court construed “buffer” as “short term storage associated with said requested SM object,” determined that claim 16 required both a specialized buffer and a specific order of steps, and again granted summary judgment for noninfringement.On the present appeal, the United States Court of Appeals for the Federal Circuit held that the district court erred in limiting the claim to a specialized buffer, but correctly construed the claim to require the first two steps to be performed in sequence. Because the accused system did not perform the steps in this required order, the Federal Circuit affirmed the district court’s judgment of noninfringement. View "Sound View Innovations, LLC v. Hulu, LLC" on Justia Law

The plaintiff, owner of U.S. Patent No. 7,679,637, claimed infringement by the defendant, Google LLC, concerning a patent related to web conferencing systems. The patent describes systems that allow participants to view sessions in real time, with time-shifting capabilities so that sessions can also be viewed with delay or after completion, and at different playback rates while maintaining consistent audio quality. The asserted claims permit asynchronous review of multimedia presentations, such as going back to review one aspect while another continues live.The United States District Court for the Western District of Washington reviewed the complaint, in which the plaintiff alleged infringement of claims 2–5 and 7–9 of the patent. Google moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing the asserted claims were patent-ineligible under 35 U.S.C. § 101. The district court granted the motion to dismiss, finding the claims were directed to an abstract idea without an inventive concept that would make them patent-eligible. The court also denied the plaintiff leave to amend the complaint, citing futility.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s dismissal de novo, applying the Alice two-step test for patent eligibility. The appellate court affirmed that the claims were directed to the abstract idea of asynchronous review of presentations and did not disclose a specific technological improvement or inventive concept. The court found that conventional components and result-oriented language did not suffice for eligibility and agreed that amendment of the complaint would be futile. The Federal Circuit affirmed the district court’s dismissal of the case. Costs were awarded to Google. View "US PATENT NO. 7,679,637 LLC v. GOOGLE LLC " on Justia Law

A physician brought suit against several related companies, alleging that they induced surgeons to infringe claims of three patents covering surgical techniques and tools for treating spinal deformities. These patents involve methods and devices for correcting misaligned vertebrae, including the use of “handle means” and “cross-linking members” in en bloc derotation procedures. The defendant companies manufacture derotation devices that, according to the plaintiff, infringe the asserted patents when used in certain configurations. The dispute centered on whether the accused devices contained the claimed “handle means” and whether surgeons actually used the devices in infringing ways.In the United States District Court for the Eastern District of Pennsylvania, the parties disputed the meaning of “handle means,” and the court adopted the plaintiff’s proposed construction. During the trial, the plaintiff presented testimony from two experts: one on infringement and another who conducted a survey on surgical practices. The defendants moved to exclude both experts under Daubert, challenging the reliability and relevance of their methods and opinions. Initially, the district court denied these motions, finding that the experts’ application of the court’s claim construction and survey methodology affected the weight of their testimony, not its admissibility.However, following the experts’ testimony at trial, the district court reversed its earlier decision, excluded substantial portions of both experts’ testimony as unreliable and contradictory to the court’s claim construction, and then granted judgment as a matter of law to the defendants due to the lack of admissible evidence supporting infringement.On appeal, the United States Court of Appeals for the Federal Circuit held that the district court abused its discretion in excluding the expert testimony and erred in granting judgment as a matter of law. The appellate court reversed the district court’s rulings, holding that the excluded testimony did not contradict the court’s claim construction and that any methodological concerns went to evidentiary weight, not admissibility. The case was remanded for a new trial in which both experts may testify. View "BARRY v. DEPUY SYNTHES COMPANIES " on Justia Law

Crocs, Inc. owns two U.S. trademarks covering features of its Classic Clog shoes. In June 2021, Crocs filed a complaint with the United States International Trade Commission (ITC), alleging that several respondents violated Section 337 of the Tariff Act of 1930 by importing or selling footwear that infringed or diluted Crocs’s trademarks. Crocs sought a general exclusion order (GEO) or, in the alternative, a limited exclusion order (LEO). During the investigation, some respondents were found in default for failing to participate, while others actively defended against the claims.An Administrative Law Judge conducted an evidentiary hearing for the three active respondents and, in January 2023, issued an Initial Determination finding no violation of Section 337. The judge concluded that Crocs had not shown infringement or dilution of its trademarks and had waived infringement contentions against the defaulting respondents. The Commission reviewed parts of this determination and, in September 2023, issued a final decision: it found no violation by the active respondents and determined not to apply the waiver to the defaulting respondents. For the defaulting respondents, the ITC presumed the facts in Crocs’s complaint to be true, as required by statute, and issued an LEO against them, finding no public interest factors weighed against exclusion.On appeal, Crocs challenged both the no violation finding as to active respondents and the issuance of only an LEO rather than a GEO for the defaulting respondents. The United States Court of Appeals for the Federal Circuit held that Crocs’s appeal regarding the active respondents was untimely and dismissed it. Regarding the defaulting respondents, the court affirmed the Commission’s decision to issue a limited exclusion order, finding no abuse of discretion or error in law. Thus, the appeal was dismissed in part and affirmed in part. View "CROCS, INC. v. ITC " on Justia Law

The Massachusetts Institute of Technology owns three patents related to fuel management systems for spark ignition engines, which are exclusively licensed to Ethanol Boosting Systems, LLC. These patents describe a system that uses both direct and port fuel injection to mitigate engine knock and optimize performance. The system operates with varying injection mechanisms depending on engine torque or manifold pressure, and includes a three-way catalyst to reduce emissions. The patents contain claims focusing on the interplay of injection types with engine operating ranges and the use of anti-knock agents.Previously, Ford Motor Company petitioned the Patent Trial and Appeal Board (PTAB) for inter partes review (IPR) of all three patents. The PTAB initially denied institution, largely due to a claim construction that restricted the definition of “fuel” in a manner consistent with a district court’s prior interpretation, which required the directly injected fuel to differ from the port-injected fuel and to contain an anti-knock agent other than gasoline. After the Federal Circuit, in Ethanol Boosting Sys., LLC v. Ford Motor Co., vacated the district court’s construction regarding the “different fuel” requirement (but did not address the anti-gasoline requirement), the PTAB granted Ford’s rehearing request and instituted the IPRs.On appeal from the PTAB, the United States Court of Appeals for the Federal Circuit reviewed the Board’s final written decisions, which found the relevant claims of all three patents unpatentable as obvious. The Federal Circuit rejected EBS’s arguments that the Board lacked authority to delay its rehearing decision and that the Board was bound by the non-appealed portion of the district court’s claim construction. The court affirmed the Board’s adoption of the plain and ordinary meaning of the disputed terms and found substantial evidence supporting the Board’s factual findings regarding obviousness. The holding is that the PTAB’s decisions finding all challenged claims unpatentable as obvious are affirmed. View "ETHANOL BOOSTING SYSTEMS, LLC v. FORD MOTOR COMPANY " on Justia Law

Micron Technology and its subsidiaries, along with the State of Idaho, were sued for patent infringement by Katana Silicon Technologies in the United States District Court for the Western District of Texas. The patents at issue related to technology for shrinking semiconductor devices and had expired. In response, Micron asserted a counterclaim under the Idaho Bad Faith Assertions of Patent Infringement Act, alleging that Katana had made bad faith assertions of patent infringement. Katana moved to dismiss the counterclaim, arguing that the Idaho Act was preempted by federal patent law. The case was transferred to the United States District Court for the District of Idaho, where the State of Idaho intervened to defend the statute. Separately, Micron filed suit in Idaho state court against Longhorn IP, alleging similar bad faith assertions and seeking the imposition of a bond. Longhorn removed that case to federal court and also moved to dismiss on preemption grounds.The United States District Court for the District of Idaho denied both motions to dismiss, holding that federal law did not preempt the Idaho statute. The court also imposed an $8 million bond on Longhorn and Katana pursuant to the Act, finding that there was a reasonable likelihood that a bad faith assertion of patent infringement had occurred. Katana and Longhorn appealed these decisions to the United States Court of Appeals for the Federal Circuit.The United States Court of Appeals for the Federal Circuit dismissed the appeal for lack of jurisdiction. The appellate court determined that there was no final judgment from the district court, as the only decisions made were the denial of motions to dismiss and the imposition of a bond, neither of which ended the litigation on the merits. The Federal Circuit also found that none of the exceptions for interlocutory appellate review applied, including those for injunctions, the collateral order doctrine, or mandamus, nor was pendent jurisdiction appropriate. View "Micron Technology, Inc. v. Longhorn IP LLC" on Justia Law

Wonderland Switzerland AG owns two patents related to child car seats, U.S. Patent Nos. 7,625,043 and 8,141,951. Wonderland sued Evenflo Company, Inc., alleging that five Evenflo convertible car seat models, categorized as “4-in-1” and “3-in-1” seats, infringed claims of both patents. The dispute focused on specific features of the accused car seats, such as mechanisms for attaching the seat back to the seat assembly and the structure of engaging components.A jury in the United States District Court for the District of Delaware found that both Evenflo’s 3-in-1 and 4-in-1 seats infringed claim 1 of the ’043 patent under the doctrine of equivalents and that the 4-in-1 seats also infringed claims 1 and 5 of the ’951 patent, both literally and under the doctrine of equivalents. The jury found Evenflo’s infringement of the ’043 patent was not willful. The district court denied both parties’ motions for judgment as a matter of law and for a new trial, granted a permanent injunction covering both patents, and denied Wonderland’s motion for a new trial on willful infringement.On appeal, the United States Court of Appeals for the Federal Circuit reversed the judgment that Evenflo’s 4-in-1 seats infringe claim 1 of the ’043 patent under the doctrine of equivalents, finding no substantial evidence supported the jury’s verdict on that point. The court also reversed the permanent injunction as to both patents because the injunction for the ’951 patent was not requested and the showing for irreparable harm as to the ’043 patent was insufficient. Furthermore, the court reversed the denial of a new trial on willful infringement of the ’043 patent (for the 3-in-1 seats only) due to wrongful exclusion of key evidence. The judgment was otherwise affirmed, and the case was remanded for further proceedings. View "WONDERLAND SWITZERLAND AG v. EVENFLO COMPANY, INC. " on Justia Law