Justia Intellectual Property Opinion Summaries

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

Amphastar Pharmaceuticals Inc. and its wholly owned subsidiary (collectively, Amphastar) and Sandoz Inc. were competitors in the U.S. market for generic enoxaparin, an anticoagulant. Momenta Pharmaceuticals Inc. served as Sandoz’s contract laboratory. Amphastar filed a complaint alleging antitrust violations by Sandoz and Momenta based on Defendants’ alleged misrepresentations to the United States Pharmacopeial Convention, a private standard-setting organization charged with ensuring the quality of drugs. Defendants brought an infringement suit against Amphastar, resulting in a temporary restraining order (TRO) and preliminary injunction prohibiting Amphastar from selling enoxaparin. The preliminary injunction was later vacated, but it did prevent Amphastar from selling its generic enoxaparin for approximately three months. Amphastar then filed this suit under the Sherman Act seeking damages for lost profits during the pendency of the TRO and injunction. The district court dismissed the complaint under the Noerr-Pennington doctrine, which immunizes good-faith petition of government entities from antitrust liability. The First Circuit reversed, holding that the district court erred in applying Noerr-Pennington. Remanded for the district court to consider Defendants’ other arguments in the first instance. View "Amphastar Pharmaceuticals, Inc v. Momenta Pharmaceuticals, Inc." 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

Plaintiff owned AIA-LOGO! Promotions, LLC and defendant owned Insignia Marketing, Inc. Plaintiff filed suit against defendant, claiming breach of a partnership agreement, and defendant counterclaimed for breach of the same partnership agreement. Insignia then initiated a separate suit against plaintiff and Logo Promotions for trademark infringement, copyright infringement, cyber piracy, false advertising, and civil conspiracy. The jury found that plaintiff, but not defendant, had breached the partnership agreement, and awarded $60,000 in damages; found, however, that neither plaintiff nor Logo Promotions had infringed Insignia's trademark; found that Insignia had obtained registration of the "Communicat-R" trademark through fraud, that the mark was not in use on the day it was registered, and that Insignia had abandoned the mark after registration, all supporting cancellation of the registration; and found plaintiff and Logo Promotions liable for false advertising, but not cyber piracy or civil conspiracy. The trial court subsequently denied plaintiff attorneys' fees and reaffirmed its finding of waiver and, in the alternative, that the case was not "exceptional" enough to warrant such an award under the Lanham Act, 15 U.S.C. 1051 et seq. Defendant moved for a partial new trial and plaintiff moved for a renewed judgment as a matter of law, both of which the trial court denied. The court affirmed the denial of defendant's motion for a new trial to the extent that the motion was based on errors in the trial and jury instructions; affirmed the denial of defendant's motion for a new trial to the extent that the motion challenged the jury’s verdict as against the great weight of the evidence; affirmed the denial of plaintiff's renewed motion for judgment as a matter of law; affirmed the trial court's equal division of the interpleaded funds; and affirmed the denial of attorneys' fees. View "Vetter v. McAtee" on Justia Law

Promega sublicensed a patent, which claims a toolkit for genetic testing, to Life Technologies for the manufacture and sale of kits for use in licensed law enforcement fields worldwide. One of the kit’s five components, an enzyme, was manufactured by Life Technologies in the U.S. and shipped to the United Kingdom, where the other components were made, for combination there. When Life Technologies began selling kits outside the licensed fields of use, Promega sued, citing section 271(f)(1) of the Patent Act, which prohibits the supply from the U.S. of “all or a substantial portion of the components of a patented invention” for combination abroad. The district court held that the section did not encompass the supply of a single component of a multicomponent invention. The Federal Circuit reversed, reasoning that a single important component could constitute a “substantial portion” of the components of an invention. The Supreme Court reversed. The supply of a single component of a multicomponent invention for manufacture abroad does not give rise to liability under section 271(f)(1), which refers to a quantitative measurement. The Court rejected Promega’s proffered “case-specific approach,” which would require a factfinder to decipher whether the components at issue are a “substantial portion” under either a qualitative or a quantitative test. When a product is made abroad and all components but a single commodity article are supplied from abroad, the activity is outside the statute’s scope. View "Life Technologies Corp. v. Promega Corp." on Justia Law

The Axcess patent, entitled “System and Method for Authenticating a Web Page,” relates to "systems and methods for authenticating a web page.” The Patent Trial and Appeal Board determined that it was a covered business method (CBM) patent under the America Invents Act (AIA), 125 Stat. 284, and that certain claims were unpatentable as obvious under prior art. The Board rejected a claim by Axcess that the patent was ineligible for CBM review because it was not directed to a financial product or service and can be used by institutions other than financial institutions. The Federal Circuit reversed, finding that the Board’s characterization of a CBM was inconsistent with the statutory definition: a patent that claims a method or corresponding apparatus for performing data processing or other operations used in the practice, administration, or management of a financial product or service. If a CBM patent is to be usefully distinguished from all other patents, the distinction will not lie based on non-statutory phrases like “incidental to” or “complementary to” financial activity. Necessarily, the statutory definition of a CBM patent requires that the patent have a claim that contains, however phrased, a financial activity element. View "Secure Axcess, LLC v. PNC Bank National Association" on Justia Law

Scag, which manufactures commercial riding lawnmowers, developed a suspended operator platform for a ride-on lawnmower or other riding light utility vehicle connected to a rigid chassis by a suspension system. The operator platform supports the entire body of the operator. The suspension system suspends the operator platform from the chassis in a manner that isolates an operator from vibrations, or shock loads, generated by the mower during use or when driven over uneven terrain. The operator platform can suspend or isolate some controls from the rigid chassis. Scag commercialized the system, which is disclosed in the 475 patent, in its Cheetah line of lawnmowers. In 2015, Toro introduced riding lawnmowers with suspended operator platforms to compete with Scag’s Cheetah line. The steering controls in Toro’s riding lawnmowers are connected to the chassis, not the operator platform. Scag filed an infringement action and obtained a preliminary injunction. The Federal Circuit affirmed, finding that Scag established a likelihood of success that the accused products infringe claim 21 of the 475 patent and that there is not a substantial question of validity as to claim 21. View "Metalcraft of Mayville, Inc. v. Toro Co." on Justia Law