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

Future Link Systems, LLC entered into a license agreement with MediaTek, Inc. in 2019, which stipulated that MediaTek would pay Future Link a lump sum if Future Link filed a lawsuit against Realtek Semiconductor Corporation. Future Link subsequently filed a complaint with the International Trade Commission (ITC) accusing Realtek of patent infringement. During the litigation, Future Link settled with a third party and informed Realtek, leading Realtek to file a motion for sanctions against Future Link before the administrative law judge (ALJ).The ALJ expressed concerns about the legality of the agreement between Future Link and MediaTek but ultimately denied Realtek's motion for sanctions, concluding that the agreement did not influence Future Link's decision to file the complaint. Future Link then withdrew its complaint and moved to terminate the investigation, which the ALJ granted. The ITC terminated the investigation when no petition for review was filed. Realtek petitioned the ITC to review the ALJ's order denying sanctions, but the ITC declined and terminated the sanctions proceeding.Realtek appealed to the United States Court of Appeals for the Federal Circuit, seeking an order for Future Link to pay a fine to the Commission. The Federal Circuit concluded that it lacked jurisdiction to hear Realtek's appeal, as the Commission's decision on sanctions was not a "final determination" under 19 U.S.C. § 1337(c) that would affect the exclusion or non-exclusion of articles from entry. The court dismissed the appeal, noting that jurisdiction over such matters likely lies with the district courts, not the Federal Circuit. View "Realtek Semiconductor Corp. v. International Trade Commission" on Justia Law

In this case, the appellants, a group of German steel companies, challenged the U.S. Department of Commerce's determination of a 22.9 percent antidumping duty on their steel plate products. Commerce applied an adverse inference based on the appellants' failure to provide complete manufacturer information for certain sales by their affiliated reseller, which Commerce deemed necessary for calculating the dumping margin.The U.S. Court of International Trade (Trade Court) sustained Commerce's decision, finding that the appellants did not cooperate to the best of their ability. The Trade Court noted that the appellants failed to provide reasonable alternative forms of the missing information, which could have mitigated the burden of manually retrieving the data. The court suggested that a statistical analysis or randomized sampling could have been a reasonable alternative.The United States Court of Appeals for the Federal Circuit reviewed the case and held that Commerce's request for the missing manufacturer information imposed an unreasonable burden on the appellants. However, the court also found that the appellants did not propose reasonable alternative forms of the missing data as required by statute. Consequently, Commerce's application of adverse facts available was deemed permissible.The Federal Circuit affirmed Commerce's use of the highest non-aberrational net price among the disputed sales to fill the information gap, concluding that this approach was reasonable given the size of the information gap and the need to deter non-cooperation. The court found that Commerce's choice of adverse inference was supported by substantial evidence and in accordance with the law. View "AG DER DILLINGER HUTTENWERKE v. US " on Justia Law

Optis Cellular Technology, LLC, Optis Wireless Technology, LLC, PanOptis Patent Management, LLC, Unwired Planet International Limited, and Unwired Planet, LLC (collectively, “Optis”) sued Apple Inc. (“Apple”) for patent infringement in the U.S. District Court for the Eastern District of Texas. Optis asserted that various Apple products implementing the LTE standard infringed five of its standard-essential patents. The jury found Apple infringed certain claims of the asserted patents and awarded $506,200,000 in damages. Apple moved for a new trial, arguing the jury did not hear evidence regarding Optis’s obligation to license the patents on FRAND terms. The district court granted a new trial on damages, and the jury awarded $300,000,000 in the retrial.The United States Court of Appeals for the Federal Circuit reviewed the case. The court vacated both the infringement and second damages judgments, remanding for a new trial on infringement and damages. The court dismissed Optis’s cross-appeal to reinstate the original damages verdict. The court also reversed the district court’s findings that claims 6 and 7 of the ’332 patent are not directed to an abstract idea under 35 U.S.C. § 101 and that claim 1 of the ’557 patent does not invoke 35 U.S.C. § 112 ¶ 6. The court affirmed the district court’s construction of claim 8 of the ’833 patent. Additionally, the court concluded that the district court abused its discretion by admitting the Apple-Qualcomm settlement agreement and related expert testimony into evidence.The Federal Circuit held that the single infringement question on the verdict form violated Apple’s right to a unanimous verdict, as it did not ensure all jurors agreed on the same patent being infringed. The court also determined that claims 6 and 7 of the ’332 patent are directed to an abstract idea and remanded for further analysis under Alice step two. The court found that “selecting unit” in claim 1 of the ’557 patent invokes § 112 ¶ 6 and remanded for further proceedings. View "OPTIS WIRELESS TECHNOLOGY, LLC v. APPLE INC. " on Justia Law

Anthony Stuart, a Navy veteran, appealed a decision by the Merit Systems Protection Board (MSPB) that denied him credit for his military service in computing his civilian retirement annuity. Stuart served in the Navy during three periods between 1974 and 1991 and was placed on the Permanent Disability Retirement List in 1994 with a 60% disability rating. He later entered federal civilian service and retired in 2015. Stuart did not waive his military retired pay to receive credit for his military service toward his Federal Employees’ Retirement System (FERS) annuity.The Office of Personnel Management (OPM) initially decided that Stuart’s military service was not creditable toward his FERS annuity because he was receiving military retired pay. OPM explained that by statute, Stuart could not receive both military retired pay and FERS credit for his military service unless his military retired pay was awarded for specific reasons, which did not apply to him. Stuart sought reconsideration, but OPM affirmed its decision. Stuart then appealed to the MSPB, where an administrative judge upheld OPM’s decision, and the full Board affirmed, modifying the initial decision to clarify the analysis.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the MSPB’s decision. The court held that under 5 U.S.C. § 8411(c)(2), Stuart’s military service could not be credited toward his FERS annuity because he was receiving military retired pay and did not meet any statutory exceptions. The court rejected Stuart’s argument that his military retired pay, calculated based on his disability percentage, was not “based on” his military service. The court found that the statute clearly barred double crediting of military service for both military retired pay and a civilian retirement annuity. View "STUART v. OPM " on Justia Law

United Services Automobile Association (USAA) owns U.S. Patent No. 10,402,638, which is directed to remote check deposit technology. The patent describes a system where a customer uses a personal mobile device to take a picture of a check and transmit the image to a financial institution. The system includes steps for error checking and optical character recognition (OCR) to ensure the check image is of sufficient quality. USAA sued PNC Bank, N.A. for infringement of this and other patents.The United States District Court for the Eastern District of Texas granted USAA’s motion for summary judgment, finding the asserted claims patent-eligible under 35 U.S.C. § 101. The court denied PNC’s cross-motion for summary judgment. A jury trial followed, where the jury found no invalidity and that PNC had infringed USAA’s patents. PNC appealed the district court’s summary judgment ruling on § 101.The United States Court of Appeals for the Federal Circuit reviewed the case and reversed the district court’s decision. The Federal Circuit held that the asserted claim of the ’638 patent is directed to the abstract idea of depositing a check using a handheld mobile device and does not contain an inventive concept sufficient to transform the abstract idea into a patent-eligible application. The court concluded that the claim recites routine data collection and analysis steps implemented by a generic device, which is insufficient for patent eligibility under § 101. Consequently, the Federal Circuit reversed the district court’s grant of summary judgment and did not address USAA’s cross-appeal regarding damages testimony. View "UNITED SERVICES AUTOMOBILE ASSOCIATION v. PNC BANK N.A. " on Justia Law

Mitek Systems, Inc. (Mitek) filed a declaratory judgment action against United Services Automobile Association (USAA) seeking a declaration of non-infringement concerning four patents related to its MiSnap software product. Mitek argued that it faced potential liability for direct, induced, and contributory infringement, as well as indemnification demands from its licensees after USAA sent them letters seeking to sell licenses to USAA patents.The United States District Court for the Eastern District of Texas initially dismissed Mitek’s complaint for lack of subject-matter jurisdiction and alternatively declined to exercise jurisdiction. On appeal, the Federal Circuit vacated the dismissal and remanded for further proceedings, instructing the district court to conduct a more detailed analysis. On remand, the district court again dismissed the case, finding no subject-matter jurisdiction and reiterating its decision to decline jurisdiction even if it existed.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the district court’s decision. The court agreed that Mitek did not have a reasonable apprehension of suit for direct, induced, or contributory infringement based on the record evidence, including USAA’s allegations and claim charts from prior litigation. The court also found that Mitek’s potential indemnification liability was not sufficient to establish jurisdiction, as the indemnification agreements contained applicable carve-outs and did not create a reasonable potential for liability. Additionally, the court upheld the district court’s discretionary decision to decline jurisdiction, noting that intervention in future litigation involving Mitek’s customers would be a more effective remedy. View "MITEK SYSTEMS, INC. v. UNITED SERVICES AUTOMOBILE ASSOCIATION " on Justia Law

Agilent Technologies, Inc. appealed two final written decisions by the Patent Trial and Appeal Board (Board) that determined all claims of U.S. Patent Nos. 10,337,001 and 10,900,034 to be unpatentable. The patents in question relate to CRISPR-Cas systems for gene editing, specifically focusing on chemically modified guide RNAs (gRNAs) used in these systems. The Board found that the claims were anticipated by prior art, specifically a reference known as Pioneer Hi-Bred, and that certain claims were also obvious in view of additional references, Threlfall and Deleavey.The Board's decisions were based on findings that Pioneer Hi-Bred disclosed the claimed gRNA functionality and that the reference was enabling. The Board also found that the additional references provided sufficient motivation and reasonable expectation of success for a person of ordinary skill in the art to combine the teachings of Pioneer Hi-Bred with those of Threlfall and Deleavey.The United States Court of Appeals for the Federal Circuit reviewed the Board's findings. The court affirmed the Board's determination that Pioneer Hi-Bred disclosed the claimed gRNA functionality, noting that substantial evidence supported the Board's findings. The court also agreed with the Board's conclusion that Pioneer Hi-Bred was an enabling reference, rejecting Agilent's arguments that undue experimentation would be required to practice the disclosed invention.Additionally, the court upheld the Board's finding that the dependent claims, which included specific chemical modifications, were obvious in view of the combined teachings of Pioneer Hi-Bred, Threlfall, and Deleavey. The court found that the Board had provided a thorough analysis and that substantial evidence supported the Board's conclusion that a person of ordinary skill in the art would have had a reasonable expectation of success in making the claimed modifications.In conclusion, the Federal Circuit affirmed the Board's decisions, holding that all claims of the '001 and '034 patents were unpatentable. View "AGILENT TECHNOLOGIES, INC. v. SYNTHEGO CORP. " on Justia Law

Albert Lobo, a Deputy Sheriff in San Bernardino County, California, contracted pneumonia in early 2010, which progressed to sepsis and resulted in multiple amputations, leaving him permanently and totally disabled. He received disability retirement and workers' compensation benefits at the county and state levels between 2012 and 2014. In March 2015, Lobo filed a claim for disability-based benefits under the Public Safety Officers’ Benefits Act of 1976 (PSOB Act) with the Public Safety Officers’ Benefits Office (PSOB Office) of the Bureau of Justice Assistance (Bureau) of the U.S. Department of Justice.The PSOB Office denied Lobo's claim in May 2016, a decision upheld by a hearing officer in October 2017 and the Bureau’s Director in August 2023. The denials were based on the finding that Lobo had not proven he contracted pneumonia in the line of duty. The Bureau's Director emphasized the lack of evidence showing that Lobo caught pneumonia at the jails where he worked, despite acknowledging that Lobo was permanently and totally disabled due to pneumonia.The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the Bureau had not made sufficient efforts to obtain potentially crucial information about whether there were pneumonia-infected individuals at the jails where Lobo worked. The court noted that such information could be highly material to determining the origin of Lobo's pneumonia. Consequently, the court vacated the Director’s decision and remanded the case for further proceedings, instructing the Bureau to make reasonable efforts to obtain the necessary information from the jails and to reassess the claim in light of any new evidence obtained. View "Lobo v. Department of Justice" on Justia Law

Fraunhofer-Gesellschaft zur Förderung der angewandten Forschung e.V. (Fraunhofer) is a non-profit research organization that developed and patented multicarrier modulation (MCM) technology used in satellite radio. In 1998, Fraunhofer granted WorldSpace International Network, Inc. (WorldSpace) an exclusive license to its MCM technology patents. Fraunhofer also collaborated with XM Satellite Radio (XM) to develop a satellite radio system, requiring XM to obtain a sublicense from WorldSpace. XM later merged with Sirius Satellite Radio to form Sirius XM Radio Inc. (SXM), which continued using the XM system. In 2010, WorldSpace filed for bankruptcy, and Fraunhofer claimed the Master Agreement was terminated, reverting patent rights to Fraunhofer. In 2015, Fraunhofer notified SXM of alleged patent infringement and filed a lawsuit in 2017.The United States District Court for the District of Delaware initially dismissed the case, ruling SXM had a valid license. The Federal Circuit vacated this decision and remanded the case. On remand, the district court granted summary judgment for SXM, concluding Fraunhofer's claims were barred by equitable estoppel due to Fraunhofer's delay in asserting its rights and SXM's reliance on this delay to its detriment.The United States Court of Appeals for the Federal Circuit reviewed the case and reversed the district court's summary judgment. The Federal Circuit agreed that Fraunhofer's delay constituted misleading conduct but found that SXM did not indisputably rely on this conduct in deciding to migrate to the high-band system. The court noted that SXM's decision was based on business pragmatics rather than reliance on Fraunhofer's silence. The case was remanded for further proceedings to determine if SXM relied on Fraunhofer's conduct and if it was prejudiced by this reliance. View "Fraunhofer-Gesellschaft v. Sirius XM Radio Inc." on Justia Law

Abigail Stratton filed a petition with the Office of Special Masters under the National Childhood Vaccine Injury Act, alleging that the Gardasil® vaccine caused her to develop postural orthostatic tachycardia syndrome (POTS) and autonomic dysfunction. These conditions are not listed in the Vaccine Injury Table, requiring her to prove actual causation by a preponderance of the evidence. After filing a Notice of Intent to Withdraw to pursue her claim in federal district court, the Chief Special Master concluded the proceedings on the merits and later awarded her partial attorneys’ fees and costs.The Secretary of Health and Human Services opposed the fee application, arguing that Stratton did not file her petition with the good faith intent of litigating the claim and that there was no reasonable basis for her claim. The Chief Special Master found that Stratton had satisfied both the good faith and reasonable basis requirements and awarded partial fees. The Court of Federal Claims affirmed the Chief Special Master’s decision, concluding that the finding of a reasonable basis was not arbitrary and capricious, and awarded $8,876.86 for attorneys’ fees and costs. The Secretary appealed this decision.The United States Court of Appeals for the Federal Circuit reviewed the case and found that the Chief Special Master failed to adequately explain the determination that Stratton’s petition had a reasonable basis. The court noted that the Chief Special Master acknowledged the Secretary’s concerns about the sufficiency of the medical records but dismissed them without sufficient explanation. The Federal Circuit vacated the decision and remanded the case for further proceedings consistent with its opinion, requiring a more detailed explanation of why the evidence provided a reasonable basis for Stratton’s claim. View "Stratton v. Health and Human Services" on Justia Law