Justia Intellectual Property Opinion Summaries

The patents-in-suit relate to soybeans genetically engineered to tolerate herbicide, and, particularly, to the Bayer-developed dmmg gene. The parties disagreed over the scope of Bayer’s license of the patents to MS Tech, specifically, whether the license granted MS Tech a broad license to commercialize and sublicense the soybean technology. MS Tech had sublicensed to Dow. When Bayer sued Dow for infringement, Dow raised that sublicense as an affirmative defense. The district court entered summary judgment in favor of Dow; the Federal Circuit affirmed. The district court then awarded Dow attorney fees under 35 U.S.C. 285, declaring this an "exceptional case.” The Federal Circuit affirmed, noting Bayer’s weak positions on the merits and litigation conduct. “Bayer’s own witnesses as well as key documents contradicted Bayer’s contorted reading of the contract.” Bayer’s arguments were “fallacious” because they were “implausible” and “made no business sense” in light of the facts surrounding the agreements and their negotiation. View "Bayer Cropscience AG v. Dow Agrosciences LLC" on Justia Law

The patents involves simulation/emulation technology. In 1998, Mentor filed the application that would become the 376 patent. The inventors, Mentor employees, assigned the invention to Mentor; they subsequently left Mentor and founded EVE. In 2006, Mentor sued, alleging EVE’s emulation and verification system infringed its patents. The parties settled; EVE obtained a license to the patents, including a provision terminating the license if EVE were acquired by another company in the emulation industry. In 2012, Mentor learned Synopsys might acquire EVE. Mentor’s CEO contacted his Synopsys counterpart, offering to waive the license's confidentiality provision to inform Synopsys that the license would terminate if Synopsys acquired EVE. Synopsys and EVE sought a declaratory judgment that the patents were invalid and not infringed. Synopsys acquired EVE. Mentor counterclaimed willful infringement. With regard to the 376 patent, the Federal Circuit affirmed that assignor estoppel bars Synopsys from challenging its validity and upheld the infringement verdict and damages award. The court reversed summary judgment that Synopsys’ 109 patent was indefinite; affirmed summary judgment that Synopsys’ 526 patent lacks patent-eligible subject matter; vacated a ruling precluding Mentor from presenting evidence of willful infringement; reversed summary judgment that Mentor’s 882 patent lacked written description support; and reversed summary judgment that Mentor’s infringement allegations regarding the 531 and 176 patents were barred by claim preclusion. View "Mentor Graphics Corp. v. EVE-USA, Inc." on Justia Law

Nidec's patent discloses a system for controlling the torque of an electromagnetic motor. Following an inter partes review, the Patent Trial and Appeal Board found that claim 21 was anticipated. The Federal Circuit reversed that decision as not supported by substantial evidence. The Board incorrectly held that anticipation can be found even when a prior art reference fails to disclose a claim element so long as a skilled artisan reading the reference would “at once envisage” the claimed arrangement. View "Nidec Motor Corp. v. Zhongshan Broad Ocean Motor, LLC" on Justia Law

TVI’s patent discloses an inertial tracking system for tracking the motion of an object relative to a moving reference frame. Inertial sensors, such as accelerometers and gyroscopes, measure specific forces associated with changes in a sensor’s position and orientation relative to a known starting positionl they are used in various applications, including aircraft navigation and virtual reality simulations. When mounted on a moving object, inertial sensors can calculate the position, orientation, and velocity of the object in three-dimensional space, based on a specified starting point, without any other external information. The Federal Circuit reversed the Claims Court’s determination that certain claims were directed to patent-ineligible subject matter, 35 U.S.C. 101. The claims are not directed to an abstract idea, but specify a particular configuration of inertial sensors and a particular method of using the raw data from the sensors in order to more accurately calculate the position and orientation of an object on a moving platform. The mathematical equations are a consequence of the arrangement of the sensors and the unconventional choice of reference frame in order to calculate position and orientation. Far from claiming the equations themselves, the claims seek to protect only the application of physics to the unconventional configuration of sensors as disclosed. View "Thalex Visionix Inc.. v. United States" on Justia Law

Comcast sued Sprint for infringement of the Low Patents, which are in the same patent family and are generally directed to methods of using Domain Name System (DNS) technology, such as the Internet, to initiate and route a phone call through a switched telecommunication system. A jury found that Sprint’s handling of certain phone calls infringed various claims and awarded Comcast a $7.5 million damages award. The district court denied Sprint’s motion for judgment as a matter of law or for a new trial, and added prejudgment interest to the damages award. The Federal Circuit affirmed, upholding findings that “[a] system with elements of both switches and a ‘datagram-based system’ is not necessarily outside the scope of a ‘switched telecommunication system.’”; “A ‘communication system’ is still a broader concept than a ‘switched telecommunication system’ even where the ‘switched telecommunication system’ has elements of a ‘datagram-based system,’ because a ‘switched telecommunication system’ at a minimum must have switches and function on a bearer network”; and that “parsing” was an automated process because it necessarily required a computer. View "Comcast IP Holdings I LLC v. Sprint Communications Co." on Justia Law

Meiresonne is the sole inventor of the 096 patent, titled “Supplier Identification and Locator System and Method,” disclosing a “system whereby a user can identify a supplier of goods or services over the Internet.” It teaches a directory website that contains a plurality of links to supplier websites, “a supplier descriptive portion” located near a corresponding supplier link, “a descriptive title portion” describing the class of goods or services listed on the website, and “a rollover window that displays information” about at least one of the suppliers corresponding to a link. The Federal Circuit affirmed the determination of the U.S. Patent and Trademark Office’s Patent Trial and Appeal Board, on inter partes review, that four claims are unpatentable under 35 U.S.C. 103. The Board’s fact finding that prior art references do not teach away from combining text descriptions with additional information in a rollover viewing area is supported by substantial evidence. View "Meiresonne v. Google, Inc." on Justia Law

IV sued Capital One, alleging infringement of three patents. Capital One asserted antitrust counterclaims against IV under the Sherman Act and moved for summary judgment on IV’s infringement claims, arguing that the 081 and 002 patents were invalid under 35 U.S.C. 101. In a related proceeding, the district court entered a partial summary judgment order of ineligibility under section 101 for the 084 patent. The district court invalidated the 081 and 002 patents under section 101 and barred IV from proceeding on its infringement claims as to the 084 patent under a collateral estoppel theory. The Federal Circuit, having affirmed in the related proceeding, also affirmed in favor of Capital One. The partial summary judgment order with respect to the 084 patent met the finality prong for the purposes of collateral estoppel. The claims of the 081 patent are, at their core, directed to the abstract idea of collecting, displaying, and manipulating data, and are patent-ineligible; taken individually or in combination, the recited limitations neither improve the functions of the computer itself, nor provide specific programming, tailored software, or meaningful guidance for implementing the abstract concept. The court noted that the 002 patent had been found ineligible in a related proceeding. View "Intellectual Ventures I LLC v. Capital One Financial Corp." on Justia Law

IV sued insurance companies, alleging infringement of three patents. The insurers moved to dismiss IV’s 581 patent infringement claims for lack of standing and argued that all three patents were directed to ineligible subject matter under 35 U.S.C 101. After concluding that IV did not own the rights to the 581 patent, the district court dismissed those claims for lack of standing, finding that a particular assignor did not assign any rights in or to the then-pending application to the 581 patent, thus breaking a chain in ownership of the patent. The court also found the three patents ineligible under section 101. The Federal Circuit agreed that IV had not been assigned any rights in the 581 patent and lacked standing. The court also agreed that the 434 patent, reciting “no more than routine steps involving generic computer components and conventional computer data processing activities to accomplish the well-known concept of creating an index and using that index to search for and retrieve data” was patent-ineligible. The 002 patent, reciting the abstract idea of remotely accessing user-specific information, identifies a need, but the claims fail to provide a concrete solution to address that need. View "Intellectual Ventures I LLC v. Erie Indemnity Co." on Justia Law

Prism’s patents describe methods and systems for managing access to protected information provided over certain “untrusted” networks. The technology involves an access server, an authentication server, and a client. The access server forwards client requests for protected information to the authentication server. If the authentication server, using stored identity data, successfully authenticates the client, the client receives authorization to access the information. After the court construed “Internet Protocol network” and similar limitations as “an untrusted network using any protocol of the Internet Protocol Suite including at least one of IP, TCP/IP UDP/IP, HTTP, and HTTP/IP.” and defined an “untrusted” network as “a public network with no controlling organization, with the path to access the network being undefined and the user being anonymous,” a jury found Sprint liable for infringement and awarded Prism $30 million in reasonable-royalty damages under 35 U.S.C. 284. The district court denied Prism’s motion for additional monetary relief for times after the period Prism said was covered by the jury verdict. The Federal Circuit affirmed, upholding the court’s admission of evidence of a settlement between Prism and AT&T in a suit involving similar allegations and other evidentiary rulings. View "Prism Technologies LLC v. Sprint Spectrum L.P." on Justia Law

The 336 patent discloses a microprocessor with two independent clocks—a variable frequency system clock connected to the central processing unit (CPU) and a fixed-frequency clock connected to the input/output (I/O) interface. The patent teaches improving microprocessor performance by decoupling the CPU and I/O clocks, so that “optimum performance can be achieved by each.” In five separate litigations, the parties stipulated to non-infringement based on the district court’s construction of “an entire oscillator disposed upon said integrated circuit substrate.” The Federal Circuit consolidated the appeals and vacated, holding that the district court erred in a portion of its construction of “entire oscillator.” An ”entire oscillator disposed upon said integrated circuit substrate” is “an oscillator located entirely on the same semiconductor substrate as the central processing unit that does not require a command input to change the clock frequency and whose frequency is not fixed by any external crystal.” View "Technology Properties Ltd. v. Huawei Technologies Co., Ltd." on Justia Law