Justia U.S. Federal Circuit Court of Appeals Opinion Summaries

Chad Sheller, as the personal representative of the estate of his son Daniel Elias Sheller, sought attorneys' fees after voluntarily dismissing a Vaccine Act petition. Daniel passed away at two months old, two days after receiving several vaccinations. Sheller filed for compensation under the National Childhood Vaccine Injury Compensation Program, relying on the "Triple Risk Model" of vaccine-triggered sudden infant death syndrome (SIDS) proposed by Dr. Douglas Miller. This model had previously been accepted in another case, Boatmon v. Secretary of Health & Human Services.The Special Master denied Sheller's request for attorneys' fees, concluding that the Triple Risk Model did not provide a reasonable basis for the claim. The United States Court of Federal Claims affirmed this decision. The Special Master also struck certain medical articles from the record, which were submitted after the petition was dismissed, deeming them irrelevant.The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the Special Master abused his discretion by not considering whether the Triple Risk Model was a reasonable basis at the time of filing, given its prior acceptance in the Boatmon case. The court noted that the model was plausible and had succeeded before another special master, making it a reasonable basis for the petition when filed. The court also found that the Special Master did not abuse his discretion in striking the medical articles, as he assessed their relevance appropriately.The Federal Circuit vacated the decision and remanded the case for the Special Master to determine, in his discretion, whether attorneys' fees should be granted, considering the Vaccine Act's objective of maintaining access to qualified legal assistance. View "SHELLER v. HHS " on Justia Law

Herbert McCoy, Jr. applied for a Program Analyst position with the General Services Administration (GSA) but was not selected. He appealed to the Merit Systems Protection Board (the Board), claiming his veteran's preference and 30% or more Disabled Veteran status were not considered. McCoy had not filed a complaint with the Secretary of Labor before appealing to the Board.The Board's Administrative Judge (AJ) ordered McCoy to provide proof of filing a complaint with the Secretary of Labor, as required under the Veterans Employment Opportunities Act of 1998 (VEOA). McCoy failed to provide such proof. Consequently, the AJ dismissed the appeal for lack of jurisdiction. McCoy petitioned the Board for review, but the Board affirmed the AJ's decision, stating McCoy had not exhausted his Department of Labor (DOL) remedies.The United States Court of Appeals for the Federal Circuit reviewed the case. The court held that McCoy had not demonstrated he exhausted his DOL remedies, a prerequisite for the Board's jurisdiction under the VEOA. McCoy's arguments did not address this failure. The court affirmed the Board's decision, concluding it lacked jurisdiction over McCoy's petition. View "MCCOY v. MSPB " on Justia Law

NexStep, Inc. filed a lawsuit against Comcast Cable Communications, LLC, alleging infringement of nine patents, including U.S. Patent Nos. 8,885,802 and 8,280,009. The District Court for the District of Delaware granted summary judgment of non-infringement for the '802 patent after construing the term "VoIP" to require two-way voice communication, which NexStep's infringement theory did not meet. The '009 patent proceeded to a jury trial, where the jury found no literal infringement but did find infringement under the doctrine of equivalents. However, the district court granted Comcast's post-trial motion for judgment as a matter of law, finding NexStep's proof inadequate.The district court's summary judgment for the '802 patent was based on the construction of "VoIP" as requiring two-way voice communication, supported by technical dictionaries and the agreed industry standard meaning. NexStep's argument that VoIP should include one-way audio transmission was rejected. The court found no genuine dispute of material fact and granted summary judgment of non-infringement.For the '009 patent, the jury found no literal infringement but did find infringement under the doctrine of equivalents. However, the district court set aside this verdict, ruling that NexStep failed to provide the required particularized testimony and linking argument to support the doctrine of equivalents. The court found that NexStep's expert testimony was too conclusory and lacked specificity.The United States Court of Appeals for the Federal Circuit affirmed the district court's rulings. The appellate court agreed with the district court's construction of "VoIP" and its grant of summary judgment for the '802 patent. For the '009 patent, the appellate court found that NexStep's expert testimony did not meet the evidentiary requirements for the doctrine of equivalents, as it lacked particularized testimony and linking argument. The court dismissed Comcast's conditional cross-appeal related to the validity of the '009 patent. View "NEXSTEP, INC. v. COMCAST CABLE COMMUNICATIONS, LLC " on Justia Law

The case involves a dispute between two companies over the enforcement of standard-essential patents (SEPs) related to the 5G wireless-communication standard. The plaintiff, a telecommunications company, had made a commitment to license its SEPs on fair, reasonable, and non-discriminatory (FRAND) terms. The defendant, another technology company, sought an antisuit injunction to prevent the plaintiff from enforcing injunctions it had obtained in Colombia and Brazil based on these SEPs.The United States District Court for the Eastern District of North Carolina denied the defendant's request for an antisuit injunction. The district court applied a three-part framework to analyze the request, focusing on whether the domestic suit would be dispositive of the foreign actions. The court concluded that the domestic suit would not necessarily result in a global cross-license between the parties and therefore did not meet the threshold requirement for issuing an antisuit injunction.The United States Court of Appeals for the Federal Circuit reviewed the district court's decision. The appellate court vacated the district court's denial and remanded the case for further proceedings. The appellate court concluded that the district court had erred in its interpretation of the "dispositive" requirement. Specifically, the appellate court held that the FRAND commitment precludes the plaintiff from pursuing SEP-based injunctive relief unless it has first complied with its obligation to negotiate in good faith over a license to those SEPs. Since whether the plaintiff had complied with this obligation was an issue before the district court, the appellate court determined that the "dispositive" requirement was met.The appellate court did not decide whether the defendant was ultimately entitled to the antisuit injunction, leaving that determination to the district court's discretion upon further analysis. The case was remanded for the district court to consider the remaining parts of the foreign-antisuit-injunction framework. View "TELEFONAKTIEBOLAGET LM ERICSSON v. LENOVO (UNITED STATES), INC. " on Justia Law

Shamrock Building Materials, Inc. imported steel tubing from Mexico, which had a thin interior coating primarily composed of epoxy, melamine, and silicone additives. The United States Customs and Border Protection classified the tubing under heading 7306 of the Harmonized Tariff Schedule of the United States (HTSUS), which pertains to other tubes and pipes of iron or nonalloy steel. Shamrock contested this classification, arguing that the tubing should be classified under heading 8547 of the HTSUS, which covers electrical conduit tubing of base metal lined with insulating material. Customs rejected Shamrock's protests.The United States Court of International Trade reviewed the case and granted summary judgment in favor of the United States, upholding Customs' classification under heading 7306. The court found that the interior coating of the tubing did not provide significant electrical insulation, which is a requirement for classification under heading 8547. The court noted that the coating's primary function was to facilitate the installation of electrical wires by reducing friction, rather than providing electrical insulation.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the decision of the Court of International Trade. The Federal Circuit agreed with the lower court's interpretation that heading 8547 requires a commercially significant level of electrical insulation. The court found that Shamrock did not provide sufficient evidence to prove that the interior coating of the tubing provided such insulation. Consequently, the court held that the tubing was correctly classified under heading 7306 of the HTSUS. View "SHAMROCK BUILDING MATERIALS, INC. v. US " on Justia Law

Sage Acquisitions LLC ("Sage") entered into contracts with the United States Department of Housing and Urban Development ("HUD") to provide management and marketing services for properties in HUD's Real Estate Owned ("REO") disposition program. Sage was awarded three contracts for different geographic areas. Sage filed claims with the HUD contracting officer for settlement costs due to the termination for convenience of the contracts, equitable adjustments for reduced property assignments, and damages for scope reduction. Sage also claimed damages for HUD's alleged breach of a contractual option provision and a related bridge contract.The Civilian Board of Contract Appeals ("Board") denied Sage's claims. The Board held that the contracts were Indefinite Delivery/Indefinite Quantity ("IDIQ") contracts, not requirements contracts, and that HUD had met its obligations by ordering the guaranteed minimum quantities. The Board also found that HUD did not breach the contracts by issuing six-month task orders instead of one-year orders and that HUD did not breach the bridge contract by using REO alternatives.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the Board's decision. The court held that the contracts were indeed IDIQ contracts, as they explicitly stated and included guaranteed minimums. The court found that the language in the contracts did not confer exclusivity to Sage, and HUD's reservation of the right to work with other contractors was incompatible with a requirements contract. The court also held that HUD's issuance of six-month task orders was permissible under the contract terms. Finally, the court concluded that HUD did not breach the bridge contract, as Sage was aware of HUD's use of REO alternatives, and HUD's actions were based on legitimate business purposes. View "SAGE ACQUISITIONS LLC v. HUD " on Justia Law

UTTO Inc. owns a patent for methods to detect and identify underground utility lines. UTTO sued Metrotech Corp. for patent infringement and tortious interference with prospective economic advantage. The district court dismissed both claims, stating that UTTO failed to state a claim for which relief could be granted. The court found that the patent infringement claim required a fuller claim-construction analysis and that the state-law tort claim was correctly dismissed.The United States District Court for the Northern District of California initially denied UTTO's motion for a preliminary injunction, concluding that UTTO had not shown a likelihood of success on the merits of its infringement claim. The court construed the claim language to require "two or more" buried asset data points for each buried asset. Subsequently, the district court dismissed UTTO's First, Second, and Third Amended Complaints, each time granting leave to amend until the final dismissal with prejudice. The court consistently held that UTTO had not sufficiently pleaded facts to meet the "receiving" or "generating" limitations of the patent claim and failed to allege the required elements for the tortious interference claim.The United States Court of Appeals for the Federal Circuit reviewed the case. The court vacated the district court's dismissal of the patent infringement claim, stating that additional claim-construction proceedings were needed to determine the proper scope of the disputed claim language. The court noted that the specification of the patent and potential extrinsic evidence required further examination. However, the court affirmed the dismissal of the state-law tort claim, agreeing with the district court that UTTO had not plausibly alleged that Metrotech's conduct was independently wrongful. The case was remanded for further proceedings consistent with the appellate court's opinion. View "UTTO INC. v. METROTECH CORP. " on Justia Law

A Canadian company, J.D. Irving (JDI), challenged the U.S. Department of Commerce's assignment of an antidumping duty cash deposit rate of 11.59% on its softwood lumber products from Canada. This rate was determined in the final results of the second administrative review (AR 2) of an antidumping duty order. JDI argued that its cash deposit rate should remain at 1.57%, the rate assigned in the first administrative review (AR 1). JDI filed a complaint with the U.S. Court of International Trade (CIT), asserting that the CIT had jurisdiction under 28 U.S.C. § 1581(i), the court's residual jurisdiction.The CIT dismissed JDI's case for lack of subject matter jurisdiction, concluding that jurisdiction under § 1581(i) was not appropriate because jurisdiction could have been available under § 1581(c). The CIT noted that JDI's action was essentially a challenge to the final results of AR 2, which is reviewable under § 1581(c). Additionally, the CIT found that JDI had not demonstrated that the remedy provided by administrative review and binational panel review under the United States–Mexico–Canada Agreement (USMCA) would be manifestly inadequate.The United States Court of Appeals for the Federal Circuit affirmed the CIT's dismissal. The court held that the true nature of JDI's suit was a challenge to the AR 2 final results, making § 1581(c) the proper jurisdiction. The court also determined that JDI had not met its burden to show that the alternative remedies of administrative review and binational panel review would be manifestly inadequate. The court emphasized that binational panels have the authority to review and remand final antidumping determinations, and Commerce must take action consistent with the panel's decision. Therefore, the CIT's dismissal for lack of subject matter jurisdiction under § 1581(i) was affirmed. View "J.D. IRVING, LTD. v. US " on Justia Law

AlexSam, Inc. filed a complaint against Aetna, Inc. alleging that Aetna marketed Mastercard-branded and VISA-branded products that infringed two claims of AlexSam’s U.S. Patent No. 6,000,608. The patent, which expired in 2017, covers a multifunction card system using a central processing hub to perform specialized card functions through an existing banking network. AlexSam claimed that Aetna’s products infringed the patent by using this system.The U.S. District Court for the District of Connecticut dismissed AlexSam’s complaint, finding that Aetna’s Mastercard products were licensed under a 2005 agreement between AlexSam and Mastercard, and that AlexSam failed to state a plausible claim of direct infringement for the VISA products. The court concluded that the license covered all transactions involving Mastercard products and that AlexSam’s allegations against Aetna’s VISA products were implausible because they did not show that Aetna itself performed the infringing acts.The United States Court of Appeals for the Federal Circuit reviewed the case and found that the district court erred in its interpretation of the license agreement and in dismissing the claims against the VISA products. The appellate court held that the license agreement only covered transactions involving activation or adding value to an account, not all transactions involving Mastercard products. Therefore, some of the alleged infringing activities could fall outside the scope of the license. The court also found that AlexSam’s complaint sufficiently alleged that Aetna directly and indirectly infringed the patent with its VISA products, providing enough detail to make the claims plausible.The Federal Circuit vacated the district court’s dismissal of the claims related to both the Mastercard and VISA products and remanded the case for further proceedings. The appellate court emphasized that the district court must take all well-pled factual allegations as true when evaluating a motion to dismiss. View "ALEXSAM, INC. v. AETNA, INC. " on Justia Law

The case involves the importation of door thresholds by Worldwide Door Components, Inc. and Columbia Aluminum Products, LLC. These companies sought a determination from the Department of Commerce that their imported door thresholds were not subject to existing antidumping and countervailing duty orders on aluminum extrusions from China. The door thresholds in question are assemblies containing both extruded aluminum and non-aluminum components, which the companies argued should be excluded from the orders under the finished merchandise exception.The United States Court of International Trade initially reviewed the case and remanded it to the Department of Commerce for further consideration. The court found that the Department had misinterpreted the scope of the orders and failed to properly consider whether the door thresholds qualified for the finished merchandise exception. On remand, the Department again found the thresholds to be within the scope of the orders, categorizing them as subassemblies. The Court of International Trade disagreed, remanding the case multiple times for further analysis and clarification.The United States Court of Appeals for the Federal Circuit reviewed the case and found that the Department of Commerce's determination that the door thresholds were subassemblies was supported by substantial evidence. The court noted that the Department had provided a thorough analysis of the scope language and relevant record evidence, including statements from the companies themselves. The court also clarified that subassemblies and finished merchandise are mutually exclusive categories under the orders, meaning that the Department was not required to consider the finished merchandise exception once it determined the thresholds were subassemblies.The Federal Circuit reversed the Court of International Trade's second remand order and reinstated the Department of Commerce's first remand redetermination, which found the door thresholds to be subassemblies and therefore within the scope of the antidumping and countervailing duty orders. The court vacated all subsequent opinions and orders by the Court of International Trade. View "WORLDWIDE DOOR COMPONENTS, INC. v. US " on Justia Law