Justia Intellectual Property Opinion Summaries

The plaintiffs in this case, owners of a patent involving genetically engineered host cells containing recombinant DNA sequences, accused the defendants of infringing multiple claims of their patent. The technology at issue centers on human-made host cells that include a recombinant nucleic acid molecule encoding a specific adeno-associated virus (AAV) capsid protein, along with a heterologous non-AAV sequence. These recombinant molecules are created by artificially combining genetic material from different species, a process that does not occur in nature. The patented host cells are used in developing gene therapy products, including a product for treating Duchenne muscular dystrophy.The United States District Court for the District of Delaware reviewed cross-motions for summary judgment on the issue of patent eligibility under 35 U.S.C. § 101. The district court concluded that the asserted claims were ineligible for patent protection, reasoning that they were directed to a natural phenomenon. The court analogized the claims to those at issue in Supreme Court cases such as Funk Brothers Seed Co. v. Kalo Inoculant Co. and Association for Molecular Pathology v. Myriad Genetics, Inc., finding that merely combining natural sequences did not make the claimed invention patentable. The district court held that the claims lacked an inventive concept and granted summary judgment in favor of the defendants.The United States Court of Appeals for the Federal Circuit reviewed the decision de novo. The appellate court held that the patented host cells are not naturally occurring and possess markedly different characteristics from any product of nature, consistent with the Supreme Court’s guidance in Diamond v. Chakrabarty and Myriad Genetics. The Federal Circuit concluded that the claims are not directed to a natural phenomenon and are therefore patent-eligible under § 101. The court reversed the district court’s judgment and remanded the case for further proceedings. View "REGENXBIO INC. v. SAREPTA THERAPEUTICS, INC. " on Justia Law

This case concerns a patent dispute involving input devices for computers. The plaintiff, Genuine Enabling Technology LLC (GET), claimed that Sony’s PlayStation 3 and 4 controllers and consoles infringed several claims of U.S. Patent No. 6,219,730. The patent addresses the problem of limited computer resources by combining data streams from multiple input devices, such as keyboards and sensors, into a single stream. The contested claims include a means-plus-function limitation called “encoding means for synchronizing,” which requires synchronizing two input streams and encoding them into a combined data stream.The U.S. District Court for the District of Delaware handled the case initially. It interpreted the “encoding means” as a means-plus-function limitation and identified logic block 34 in Figure 4A of the patent as the corresponding structure. During litigation, GET’s expert, Dr. Fernald, failed to address most of the elements in logic block 34 when analyzing infringement, focusing primarily on the bit-rate clock signal. The district court excluded Dr. Fernald’s testimony on structural equivalence and ultimately granted Sony summary judgment of noninfringement, finding GET had not raised a genuine issue of material fact regarding infringement.The United States Court of Appeals for the Federal Circuit reviewed the district court’s grant of summary judgment de novo. The Federal Circuit affirmed the lower court’s decision, holding that GET’s infringement analysis was deficient because it did not adequately account for the full structure of logic block 34 required by the patent specification. The court emphasized that GET failed to explain why it was permissible to omit certain elements from its equivalence analysis. Thus, GET lacked sufficient evidence for a reasonable jury to find infringement. The district court’s exclusion of expert testimony and summary judgment were affirmed. View "GENUINE ENABLING TECHNOLOGY LLC v. SONY GROUP CORPORATION " on Justia Law

The dispute centers on a patented pre-lit artificial tree owned by Willis Electric Co., Ltd., which features separable, modular trunk portions that mechanically and electrically connect to one another, enabling attached lights to illuminate automatically regardless of trunk orientation. The prior art required separate mechanical and electrical connections, but Willis’ patent integrates both functions in a single step. Willis accused Polygroup of infringing claim 15 of its patent, specifically targeting Polygroup trees with the “Quick Set” feature that establishes simultaneous mechanical and electrical connections.After Willis initiated the lawsuit in the United States District Court for the District of Minnesota, Polygroup filed multiple inter partes review petitions at the Patent Trial and Appeal Board (PTAB) challenging various claims of Willis’ patent. The PTAB upheld claim 15, and the United States Court of Appeals for the Federal Circuit affirmed that finding. The district court proceedings continued with only claim 15 at issue. Polygroup filed a Daubert motion to exclude Willis’ damages expert, which was denied. At trial, the jury found claim 15 infringed and not invalid, awarding Willis over $42 million in damages. Polygroup then moved for judgment as a matter of law (JMOL) on obviousness and a new trial on damages, but the district court denied both motions.The United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL and the motion for a new trial. The court held that substantial evidence supported the jury’s finding that a skilled artisan would not have been motivated to combine prior art with coaxial barrel connectors as claimed in claim 15, thus affirming nonobviousness. The court also held that the district court did not abuse its discretion in admitting the damages expert’s testimony, finding the methodology sufficiently reliable under Rule 702. As a result, the Federal Circuit affirmed the district court’s judgment in all respects. View "WILLIS ELECTRIC CO., LTD. v. POLYGROUP LTD." on Justia Law

This case involves a challenge to the validity of a patent owned by DivX, LLC, which claims systems and methods for streaming partly encrypted media content. DivX sued Netflix, Inc. for patent infringement, leading Netflix to petition for inter partes review (IPR) before the United States Patent and Trademark Office’s Patent Trial and Appeal Board (PTAB). Netflix argued that the patent’s claims would have been obvious in view of specific prior-art references. The dispute centered on the proper construction of a claim limitation relating to the location of "encryption information" within the system described by the patent.After the IPR was instituted, the Patent Trial and Appeal Board first issued a final written decision holding that Netflix had not shown the claims were unpatentable, basing its conclusion on issues unrelated to claim construction. Netflix appealed that decision to the United States Court of Appeals for the Federal Circuit, which vacated and remanded. On remand, the Board adopted DivX’s proposed claim construction, holding that the limitation required the encryption information itself to be located within the requested portions of the selected stream of protected video, and again found in favor of DivX. Netflix appealed again.The United States Court of Appeals for the Federal Circuit reviewed the Board’s claim construction de novo. The appellate court held that the Board erred in its construction of the disputed limitation. The correct construction, the court explained, is that only the encrypted portions of the video frames, not the encryption information, must be located within the requested portions of the selected stream. The court found that, under this construction, the asserted prior art meets the limitation. The Federal Circuit therefore reversed the Board’s claim construction, vacated its decision, and remanded for further proceedings. View "NETFLIX, INC. v. DIVX, LLC " on Justia Law

Several technology companies challenged instructions issued by the Director of the United States Patent and Trademark Office (PTO) that guided the Patent Trial and Appeal Board (Board) in deciding whether to institute inter partes review (IPR) proceedings. These instructions, known collectively as the NHK-Fintiv instructions, outlined factors for the Board to consider when parallel patent litigation was occurring in district court. The challengers argued that these instructions resulted in too many denials of IPR petitions and were contrary to law, arbitrary and capricious, and issued without the required notice-and-comment rulemaking under the Administrative Procedure Act (APA).The United States District Court for the Northern District of California initially found all challenges to the PTO’s instructions to be judicially unreviewable. On appeal, the United States Court of Appeals for the Federal Circuit previously held that while the challenges based on statutory and arbitrary-and-capricious grounds were unreviewable, the claim regarding the lack of notice-and-comment rulemaking could proceed. On remand, the district court determined that the instructions were exempt from notice-and-comment requirements because they were “general statements of policy,” not substantive or legislative rules.The United States Court of Appeals for the Federal Circuit reviewed the district court’s decision de novo. The court agreed that the Director’s instructions were general statements of policy exempt from notice-and-comment rulemaking under 5 U.S.C. § 553(b). It emphasized that there is no statutory right to IPR institution, that the instructions do not bind the Director, and that the Director retains unreviewable discretion to institute or deny IPR. The court found that none of the legal standards or precedents cited by the challengers required a different result, and it affirmed the district court’s judgment rejecting the APA-based challenge. View "APPLE INC. v. SQUIRES " on Justia Law

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