Justia Intellectual Property Opinion Summaries

The case concerns two patents related to methods for preparing DNA samples for sequencing, owned by Laboratory Corporation of America Holdings, Labcorp Genetics, Inc., and The General Hospital Corporation. The patents describe techniques for enriching specific regions of DNA to make sequencing more efficient, using various types of primers and adaptors. The dispute centers on whether certain DNA preparation kits sold by Qiagen and its affiliates infringe these patents, specifically regarding the design and function of the primers used in Qiagen’s kits.After the plaintiffs filed suit in the United States District Court for the District of Delaware, alleging infringement of both patents, the case proceeded to a jury trial. The jury found that Qiagen willfully infringed the asserted claims of both patents—under the doctrine of equivalents for one patent and literally for the other—and awarded the plaintiffs approximately $4.7 million in damages. The district court denied Qiagen’s renewed motion for judgment as a matter of law (JMOL) on non-infringement, invalidity, and damages, and also denied Qiagen’s alternative request for a new trial.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL de novo. The Federal Circuit held that there was insufficient evidence to support the jury’s findings of infringement for either patent. The court determined that the district court erred in allowing the jury to interpret the claim term “identical” as “identical to a portion,” and found that the evidence did not support infringement under the doctrine of equivalents or literal infringement as required by the patent claims and their constructions. As a result, the Federal Circuit reversed the district court’s denial of JMOL of non-infringement for both patents, and remanded with instructions to grant JMOL of non-infringement. View "LABORATORY CORPORATION OF AMERICA HOLDINGS v. QIAGEN SCIENCES, LLC " on Justia Law

A group of employees at a wealth management firm in Richmond, Virginia, decided to leave their employer and establish a competing business. These employees, who had access to proprietary client information, had signed employment agreements with their former employer that included non-solicitation and confidentiality clauses. The agreements also addressed the industry-wide Protocol for Broker Recruiting, which generally allows departing financial advisors to take certain client information and solicit former clients if specific procedures are followed. However, the agreements stated that their terms would control over the Protocol in the event of any conflict. After resigning, the employees formed a new firm and began contacting their former clients, resulting in the loss of hundreds of accounts and significant assets for their previous employer.The United States District Court for the Eastern District of Virginia granted a preliminary injunction in favor of the former employer, barring the former employees and their new firm from contacting former clients or using confidential information. The district court found a strong likelihood of success on the merits of the trade secrets claims against all defendants, reasoning that even under the Protocol, the defendants’ conduct constituted impermissible “raiding.” The court also found that the employer would likely suffer irreparable harm and that the balance of equities and public interest favored injunctive relief.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s interpretation of the Protocol and the employment agreements. The Fourth Circuit held that the Protocol’s “raiding” exception applies only to actions by outside firms targeting another firm’s employees, not to employees leaving to form their own business. The court concluded that the employment agreements, not the Protocol, governed the former employees’ conduct and supported the injunction against them. However, because the new firm was not a party to those agreements, the injunction as to the new firm was vacated. Thus, the Fourth Circuit affirmed the injunction against the former employees but vacated it as to the new firm. View "Salomon & Ludwin, LLC v. Winters" on Justia Law

Quintara Biosciences, Inc. and Ruifeng Biztech, Inc. are both DNA-sequencing-analysis companies that had a business relationship from 2013 to 2019. In 2019, the relationship deteriorated, with Quintara alleging that Ruifeng locked it out of its office, took its equipment, and hired away its employees. Quintara then filed suit, asserting a claim under the federal Defend Trade Secrets Act (DTSA), alleging misappropriation of nine specific trade secrets, including customer and vendor databases, marketing plans, and proprietary technology.The United States District Court for the Northern District of California, referencing a California state law rule, ordered Quintara to disclose its alleged trade secrets with “reasonable particularity” at the outset of discovery. Dissatisfied with the specificity of Quintara’s disclosures, Ruifeng moved to strike most of the trade secrets under Federal Rule of Civil Procedure 12(f). The district court granted the motion, striking all but two of the trade secrets and effectively dismissing Quintara’s claims as to the others. The case proceeded to trial on the remaining trade secrets, and a jury found in favor of Ruifeng.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s actions. The appellate court held that the district court abused its discretion by striking Quintara’s trade secrets at the discovery stage. The Ninth Circuit clarified that, under the DTSA, whether a trade secret is identified with sufficient particularity is a question of fact to be resolved at summary judgment or trial, not at the outset of discovery. The court reversed the district court’s order striking the trade secrets, affirmed the denial of a mistrial, and remanded the case for further proceedings. The main holding is that DTSA claims should not be dismissed at the discovery stage for lack of particularity except in extreme circumstances, and Rule 12(f) does not authorize striking trade secrets in this context. View "QUINTARA BIOSCIENCES, INC. V. RUIFENG BIZTECH, INC." on Justia Law

The dispute centers on a patent for a system that automates the adjustment of selectorized dumbbells using an electric motor. The patent describes a dumbbell with stacks of weight plates on each side, a handle, and a movable selector that, when positioned, couples different numbers of plates to the handle. The innovation lies in using an electric motor, operatively connected to the selector, to move it into the desired position based on user input, thereby automating the weight selection process and addressing safety and convenience issues present in prior manual systems.The United States District Court for the District of Utah reviewed the case after the defendant moved to dismiss the complaint, arguing that the asserted patent claims were ineligible under 35 U.S.C. § 101. The district court applied the Supreme Court’s two-step framework for patent eligibility and determined that all but one claim (claim 19) were directed to an abstract idea and implemented using generic components, thus failing the eligibility test. The court granted the motion to dismiss as to claims 1–18 and 20, but denied it for claim 19, finding that the parties had not sufficiently addressed its eligibility.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s decision de novo. The Federal Circuit held that the relevant claims were not directed to an abstract idea but instead to a specific mechanical improvement in selectorized dumbbells. The court found that the claims recited a sufficiently specific structure and method, including the use of an electric motor to automate weight selection, and thus did not preempt all forms of automated weight adjustment. The Federal Circuit reversed the district court’s dismissal of claims 1–18 and 20 and remanded the case for further proceedings. View "POWERBLOCK HOLDINGS, INC. v. IFIT, INC. " on Justia Law

The dispute centers on allegations by Mondis Technology Ltd. and related entities that LG Electronics Inc. and its U.S. subsidiary infringed claims 14 and 15 of U.S. Patent No. 7,475,180. The patent describes a display unit, such as a computer monitor, that stores identification numbers in memory to control access by external devices. The key issue was whether the patent’s written description supported a claim limitation requiring an “identification number for identifying at least a type of said display unit,” as opposed to identifying a specific unit.After Mondis filed suit in the Eastern District of Texas, the case was transferred to the United States District Court for the District of New Jersey and stayed for patent reexamination. When some claims survived, litigation resumed on claims 14 and 15. A jury found the claims not invalid and infringed, awarding damages to Mondis. The district court denied LG’s motion for judgment as a matter of law (JMOL) on invalidity, relying on the presumption of validity and the jury’s ability to weigh expert testimony. The court vacated the initial damages award and ordered a retrial, after which a reduced damages award was entered. Both parties appealed.The United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL. The appellate court held that no reasonable jury could find the patent’s written description adequately supported the claim limitation requiring identification of a type of display unit. The court found that the patent only disclosed identification of specific units, not types, and that neither expert testimony nor the prosecution history provided substantial evidence to the contrary. The Federal Circuit reversed the district court’s judgment, held claims 14 and 15 invalid for lack of written description, and ordered judgment for LG. All other issues were deemed moot. View "Mondis Technology Ltd. v. LG Electronics Inc." on Justia Law

John Snyder, after working for Guardian Life Insurance Company and obtaining a national customer list (the Guardian Broker List), was employed by Beam Technologies, Inc. Snyder claims that Beam induced him to join and disclose the list, promising compensation. While at Beam, Snyder created state-specific broker lists derived from the Guardian Broker List and inadvertently included the full list in emails to several Beam employees. He did not mark the lists as confidential, restrict access, or inform Beam of their confidential nature. After his employment ended, Snyder did not attempt to recover the list or notify Beam of its confidential status, and he later confirmed to Beam’s CEO that the disclosure was intentional.Snyder sued Beam in the United States District Court for the District of Colorado, alleging misappropriation of trade secrets under federal and state law, as well as several state law claims. The district court granted summary judgment to Beam on the trade secret claims, finding Snyder failed to show he “owned” the Guardian Broker List. The court also granted Beam’s motion to exclude Snyder’s damages expert under Federal Rule of Evidence 702 and, in doing so, barred Snyder from presenting any evidence or witnesses on lost wages for his remaining claims. Snyder’s motion to reconsider this order was denied, and the parties settled or dismissed the remaining claims, leading to a final judgment.The United States Court of Appeals for the Tenth Circuit affirmed summary judgment on the trade secret claims, holding that Snyder failed to take reasonable measures to maintain the secrecy of the Guardian Broker List, a requirement under both the Defend Trade Secrets Act and the Colorado Uniform Trade Secrets Act. However, the Tenth Circuit reversed the district court’s Rule 702 order to the extent it excluded all evidence and witnesses on lost wages, finding that such a dispositive ruling required notice and the procedural protections of summary judgment. The case was remanded for further proceedings on that issue. View "Snyder v. Beam Technologies" on Justia Law

FMC Corporation owns U.S. Patent Nos. 9,107,416 and 9,596,857, which relate to insecticidal and miticidal compositions. FMC sued Sharda USA, LLC for patent infringement, alleging that Sharda's product, WINNER, infringed on these patents. The patents claim compositions comprising bifenthrin and a cyano-pyrethroid, with specific weight ratios. FMC sought a preliminary injunction to prevent Sharda from importing, marketing, selling, or distributing WINNER.The United States District Court for the Eastern District of Pennsylvania initially denied FMC's motion for a temporary restraining order and preliminary injunction. However, the court issued a claim construction of the term "composition," limiting it to stable compositions based on disclosures in the provisional application and a related patent. FMC renewed its motion, and the district court granted a temporary restraining order, which converted into a preliminary injunction. The court rejected Sharda's invalidity defenses, including anticipation and obviousness, based on the construed definition of "composition."The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the district court erred in its construction of "composition" by limiting it to stable compositions, as the asserted patents did not include the stability disclosures present in the provisional application and related patent. The Federal Circuit held that "composition" should be given its plain and ordinary meaning. Consequently, the court found that the district court's anticipation and obviousness analyses were flawed due to the erroneous claim construction.The Federal Circuit vacated the preliminary injunction and remanded the case for further proceedings, instructing the district court to reconsider Sharda's invalidity defenses under the correct claim construction. The court emphasized that Sharda only needed to raise a substantial question of invalidity to defeat the preliminary injunction. View "FMC CORPORATION v. SHARDA USA, LLC " on Justia Law

The case involves a dispute over the rights to stage adaptations of Harper Lee's novel "To Kill a Mockingbird." In 1969, Lee granted The Dramatic Publishing Company (Dramatic) the exclusive rights to develop and license a stage adaptation of the novel for non-first-class productions. Decades later, Lee terminated this grant and authorized a new stage adaptation, with Atticus Limited Liability Company (Atticus) holding the rights to produce this second adaptation. Atticus sought a declaration from the United States District Court for the Southern District of New York that its performances did not infringe on any copyright interest held by Dramatic. Dramatic argued that it retained exclusive rights under the Copyright Act's derivative works exception and that Atticus's acquisition of rights was invalid.The district court rejected Dramatic's arguments, ruling in favor of Atticus and awarding it attorney's fees. Dramatic appealed the judgment on the merits and both parties cross-appealed the award of attorney's fees.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's judgment granting declaratory relief to Atticus, holding that Dramatic's exclusive rights did not survive Lee's termination of the 1969 grant. The court found that the derivative works exception did not preserve Dramatic's exclusive license to stage non-first-class productions after the termination. The court also rejected Dramatic's arguments regarding the invalidity of the 2015 grant to Atticus and the timeliness of Atticus's claim.Regarding attorney's fees, the Second Circuit vacated the district court's award and remanded for further consideration. The court agreed that Dramatic's statute of limitations and res judicata arguments were objectively unreasonable but found that the district court erred in concluding that Dramatic had forfeited its statute of limitations defense and that its discovery requests unnecessarily prolonged the litigation. The court affirmed the district court's decision to deny fees incurred before April 27, 2023, and declined to award Atticus its fees on appeal. View "Atticus Ltd. Liab. Co. v. The Dramatic Publ'g Co." on Justia Law

Lance Hara, professionally known as Vicky Vox, sued Netflix, Inc. and others connected with the animated show Q-Force under the Lanham Act. Vox alleged that an animated version of her likeness appeared in a ten-second scene in the show, as well as in the official teaser and a still image promoting the series. She claimed that the unauthorized use of her image and likeness led viewers to believe that she endorsed Q-Force, constituting unfair competition and false endorsement under 15 U.S.C. § 1125.The United States District Court for the Central District of California dismissed Vox’s federal claims with prejudice, finding that Q-Force and its official teaser were expressive works entitled to heightened First Amendment protection under the Rogers test. The district court concluded that Vox failed to state a claim under the Lanham Act. The court also dismissed Vox’s state law claims for lack of subject-matter jurisdiction. Vox appealed the decision.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The court held that following the Supreme Court’s decision in Jack Daniel’s Properties, Inc. v. VIP Products LLC, the Rogers test applies when the challenged mark in an artistic work is used not to designate a work’s source but solely to perform some other expressive function. The court concluded that the defendants’ alleged use of Vox’s image and likeness in Q-Force did not suggest or identify Vox as a source or origin of the show. Under the Rogers test, the use of Vox’s likeness had artistic relevance to Q-Force, and there was no overt claim or explicit misstatement that Vox was the source of Q-Force. Therefore, Vox failed to satisfy either prong of the Rogers test. The Ninth Circuit affirmed the district court’s decision. View "HARA V. NETFLIX, INC." on Justia Law

Super Lighting sued CH Lighting for infringing three patents related to LED tube lamps. CH Lighting conceded infringement of two patents before trial. The district court excluded CH Lighting's evidence on the validity of these two patents and granted Super Lighting's motion for judgment as a matter of law (JMOL) that the patents were not invalid. A jury found the third patent infringed and not invalid, awarding damages for all three patents. CH Lighting appealed.The United States District Court for the Western District of Texas initially reviewed the case. The court excluded evidence from CH Lighting regarding the validity of the two patents and granted JMOL in favor of Super Lighting. The jury found the third patent infringed and awarded damages. CH Lighting's motions for JMOL on invalidity and for a new trial were denied, and the court doubled the damages award.The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the district court erred in granting JMOL on the validity of the two patents because it improperly excluded CH Lighting's evidence. The court held that a new trial was required to determine the validity of these patents. The court also found that substantial evidence supported the jury's verdicts of infringement and no invalidity for the third patent. Additionally, the court instructed the district court to reassess the reliability of Super Lighting's damages expert's testimony under Rule 702 of the Federal Rules of Evidence. Consequently, the court affirmed in part, reversed in part, vacated in part, and remanded the case for further proceedings. View "JIAXING SUPER LIGHTING ELECTRIC APPLIANCE, CO. v. CH LIGHTING TECHNOLOGY CO., LTD. " on Justia Law