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

This case involves a dispute over several patents relating to digital communication systems that use non-uniform constellations to increase data transmission capacity compared to traditional, uniform constellations operating within similar signal-to-noise ratio (SNR) bands. The plaintiff, Constellation Designs, LLC, alleged that several LG entities infringed claims from four patents by manufacturing and selling televisions compatible with the ATSC 3.0 standard, specifically protocol A/322, which governs over-the-air television broadcasting. The patents at issue cover two primary types of claims: those that recite methods for optimizing constellations based on parallel decode (PD) capacity (“optimization claims”), and those that recite specific, non-uniform constellations (“constellation claims”).The United States District Court for the Eastern District of Texas granted summary judgment to Constellation on patent eligibility for all asserted claims, finding them directed to a technical solution to a technical problem. At trial, a jury found the asserted claims not invalid, found infringement by LG’s accused televisions, awarded damages, and found willful infringement. LG moved for judgment as a matter of law (JMOL) on non-infringement and no damages, and sought to exclude Constellation’s damages expert, but the district court denied these motions. The court then entered final judgment and ongoing royalties.On appeal, the United States Court of Appeals for the Federal Circuit vacated the summary judgment of eligibility for the optimization claims, holding that these claims were ineligible under 35 U.S.C. § 101 because they were directed to the abstract idea of “optimizing” a constellation for PD capacity without specifying how to achieve this result. The court affirmed the eligibility of the constellation claims, finding them directed to a concrete technological solution. The Federal Circuit also affirmed the denial of JMOL on non-infringement and no damages, and the denial of the motion to exclude Constellation’s damages expert. The case was remanded for further proceedings consistent with these rulings. View "CONSTELLATION DESIGNS, LLC v. LG ELECTRONICS, INC. " on Justia Law

A U.S. citizen residing in Canada sold real estate located in Canada in 2015 and paid Canadian taxes on the resulting income. He was also required to pay the U.S. “net investment income tax” (NIIT) on the same income. To avoid double taxation, he claimed a foreign tax credit against his NIIT liability, relying on Article XXIV of the U.S.-Canada income tax treaty, which is designed to protect taxpayers from being taxed by both countries on the same income. The IRS rejected his claim for the foreign tax credit against the NIIT.The taxpayer brought a refund action in the United States Court of Federal Claims, arguing that under the treaty, he was entitled to offset his NIIT liability with the credit for Canadian taxes paid. The Court of Federal Claims granted summary judgment in his favor, holding that the treaty created a foreign tax credit that could be applied against the NIIT, thereby allowing the taxpayer to recoup the NIIT he had paid.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the text of both the Internal Revenue Code and the treaty. The court held that while the treaty’s Credit Clauses broadly apply to U.S. income taxes, the treaty expressly subjects the availability of a foreign tax credit to the limitations of U.S. law. The Code only permits foreign tax credits to offset taxes imposed by Chapter 1, and the NIIT is imposed by Chapter 2A. Thus, there is no statutory authority or independent treaty provision permitting a foreign tax credit to offset the NIIT. The court rejected arguments that the treaty overrides this limitation or that its general principle of avoiding double taxation mandates a credit against the NIIT. The Federal Circuit reversed the judgment of the Court of Federal Claims, holding that the taxpayer was not entitled to apply a foreign tax credit against the NIIT under either the Code or the treaty. View "ESTATE OF BRUYEA v. US" on Justia Law

Two U.S. citizens lived in France during the 2015 tax year and sold shares of a French company, earning a profit. They paid income taxes to both France and the United States, including a net investment income tax (NIIT) of $3,851 to the IRS. In 2020, they filed a lawsuit in the United States Court of Federal Claims seeking a refund of the NIIT, arguing that the U.S.–France tax treaty entitled them to offset that tax with credits for French income taxes paid.The United States Court of Federal Claims granted summary judgment for the plaintiffs. The court rejected their first argument based on Article 24(2)(a) of the treaty, finding it did not permit a credit against the NIIT, but accepted their second argument based on Article 24(2)(b), concluding that provision provided a credit against the NIIT without regard to certain limitations in U.S. tax law. The government appealed the judgment to the United States Court of Appeals for the Federal Circuit.The United States Court of Appeals for the Federal Circuit reviewed the treaty and statutes de novo. It held that both Article 24(2)(a) and Article 24(2)(b) of the Convention are subject to U.S. tax law limitations, specifically those in the Internal Revenue Code that prohibit offsetting the NIIT with foreign tax credits. The court reversed the judgment of the Court of Federal Claims, holding that the treaty does not provide a foreign tax credit to offset the NIIT, and the plaintiffs are not entitled to a refund on that basis. Each party was ordered to bear its own costs. View "CHRISTENSEN v. US " on Justia Law

An employee who had previously worked for the Department of State, and later for the Department of Homeland Security (DHS) as a criminal investigator, was removed from his position by DHS. The removal was based on a charge of lack of candor, relating to allegedly deceptive or incomplete responses he gave during the background investigation process, including failing to disclose an agreement with the U.S. Attorney’s Office that led to his resignation from State, and omitting details about prior criminal charges and a security clearance suspension. The employee contested the removal, arguing that his omissions were not deceptive and that he had legitimate reasons for his responses.After his removal, the employee filed a "mixed case" complaint with DHS’s Office of Diversity and Civil Rights, alleging both discrimination and non-discrimination grounds for his termination. DHS failed to meet certain regulatory deadlines for handling his complaint. The employee eventually appealed to the Merit Systems Protection Board (the Board), including a motion for sanctions against DHS for missing deadlines. The Board’s administrative judge denied the sanctions request, sustained four of the eleven specifications supporting the lack of candor charge, and upheld the penalty of removal. The full Board split, making the initial decision final and appealable.On review, the United States Court of Appeals for the Federal Circuit held that, because the employee had formally abandoned his discrimination claims, the court lacked jurisdiction to review the denial of sanctions, as those arguments were based solely on the discrimination aspects of the case. The court affirmed the Board’s findings that four specifications of lack of candor were supported by substantial evidence and that the penalty of removal was reasonable. The court dismissed the appeal as to sanctions for lack of jurisdiction and affirmed the Board in all other respects. View "JADUE v. DHS " on Justia Law

Exelixis, Inc. developed Cabometyx®, a cancer treatment containing cabozantinib (L)-malate. After identifying and characterizing crystalline and amorphous forms of this compound, Exelixis obtained several related patents. MSN Laboratories Private Limited and MSN Pharmaceuticals, Inc. sought FDA approval for a generic version using a specific polymorph of cabozantinib (L)-malate and received their own patent for that form. Exelixis sued MSN in the United States District Court for the District of Delaware, alleging infringement of patents covering crystalline cabozantinib (L)-malate salts (the “Malate Salt Patents”) and a patent directed to pharmaceutical compositions with low levels of a genotoxic impurity (the ’349 patent).The District Court held a bench trial. MSN conceded infringement of the Malate Salt Patents but argued they were invalid for lack of written description under 35 U.S.C. § 112(a). For the ’349 patent, MSN contested both infringement and validity. The District Court found the Malate Salt Patents were not invalid, holding the written description requirement was met because the patents disclosed the chemical structure, formula, and crystalline nature of the claimed salts. The court analogized its analysis to GlaxoSmithKline LLC v. Banner Pharmacaps, Inc. For the ’349 patent, the court found no infringement and no invalidity, concluding that the evidence failed to show the prior art inherently disclosed the “essentially free” impurity limitation.The United States Court of Appeals for the Federal Circuit reviewed the case. It affirmed the District Court’s finding that the asserted claims of the ’439, ’440, and ’015 patents had adequate written description support. Regarding claim 3 of the ’349 patent, the Federal Circuit dismissed MSN’s appeal as moot after Exelixis dropped its cross-appeal and vacated the District Court’s judgment of nonobviousness of that claim. The main holdings were affirmance of written description support for the asserted Malate Salt Patents and dismissal and vacatur regarding claim 3 of the ’349 patent. View "EXELIXIS, INC. v. MSN LABORATORIES PRIVATE LTD. " on Justia Law

T-Mobile and KAIFI settled a patent infringement lawsuit involving claims of U.S. Patent No. 6,922,728, which covers Wi-Fi calling technology. As part of their settlement, T-Mobile agreed to make two payments: one immediate payment and another conditional payment, the latter to be made if any of the asserted patent claims “survived” an ex parte reexamination (EPR) at the United States Patent and Trademark Office. After the Patent Office confirmed the patentability of most of the asserted claims without amendment, T-Mobile refused to make the additional payment, arguing that the claims had not truly “survived” the EPR due to alleged changes in claim scope and supposed inequitable conduct by KAIFI during the reexamination.T-Mobile filed a declaratory judgment action in the United States District Court for the Eastern District of Texas, seeking a determination that it had not breached the settlement agreement by withholding the payment. The district court granted summary judgment for KAIFI, holding that the settlement agreement was clear: a claim “survives the EPR” if the Patent Office confirms its patentability in the Reexamination Certificate. The court found T-Mobile’s arguments about claim scope and inequitable conduct irrelevant to the payment obligation and ordered T-Mobile to make the additional payment.On appeal, the United States Court of Appeals for the Federal Circuit reviewed whether it had subject-matter jurisdiction. The court determined that the dispute centered on the interpretation of a contract governed by Texas law and did not necessarily involve a substantial question of federal patent law. Consequently, the court held that it lacked appellate jurisdiction and transferred the case to the United States Court of Appeals for the Fifth Circuit, which has jurisdiction over appeals from the Eastern District of Texas. View "T-MOBILE US, INC. v. KAIFI LLC " on Justia Law

AML IP, LLC brought lawsuits in the United States District Court for the Eastern District of Texas against Bath & Body Works Direct, Inc., The Buckle, Inc., and other entities, alleging infringement of U.S. Patent No. 6,876,979. The patent concerns e-commerce methods using a “bridge computer” to facilitate transactions between service providers. Each defendant moved to dismiss the suit on two grounds: improper venue, arguing the requirements of 28 U.S.C. § 1400(b) were not satisfied, and failure to state a claim, contending the patent’s claims were ineligible under 35 U.S.C. § 101.The district court addressed both grounds. It concluded that AML had not established proper venue, justifying dismissal, and separately determined that the patent claims were ineligible for patenting, also warranting dismissal. The court entered judgment accordingly. AML filed a motion to amend the judgment, arguing the court should have dismissed only for venue and not for ineligibility after finding venue improper. The district court denied the motion, explaining it had discretion to address both grounds given they were briefed together and no alternative venue was suggested for transfer. AML appealed, challenging the district court's decision to dismiss on both grounds.The United States Court of Appeals for the Federal Circuit reviewed the appeal, applying Fifth Circuit law for procedural questions. The court held that the district court did not abuse its discretion in dismissing for both improper venue and patent ineligibility, as venue is a waivable issue and courts may resolve multiple grounds when briefed together. The appellate court also declined to address whether the merits dismissal would have preclusive effect in future cases, noting that such determinations are properly made in subsequent actions. The judgment was affirmed. View "AML IP, LLC v. BATH & BODY WORKS DIRECT, INC." on Justia Law

Several inventor-advocacy groups challenged the language used on the cover of patents issued by the United States Patent and Trademark Office (PTO), alleging that it is misleading. Specifically, they contended that the statement granting patent holders the “right to exclude others” is inaccurate following the Supreme Court’s decision in eBay Inc. v. MercExchange, L.L.C., which established that injunctions are no longer automatically granted to patent holders. The plaintiffs, all non-profit organizations supporting inventors, argued that the PTO’s failure to amend this language harms them because they must divert resources to educate their members about the true scope of patent rights.The United States District Court for the Eastern District of Virginia dismissed the case for lack of standing, holding that the plaintiffs had not shown a sufficient risk of future injury resulting from the challenged language. The district court also denied leave to amend the complaint, finding that any amendment would be futile. The plaintiffs appealed this decision.The United States Court of Appeals for the Federal Circuit affirmed the district court’s dismissal. The appellate court held that the organizations failed to demonstrate organizational standing because their alleged injury—diverting resources to educate members—was foreclosed as a basis for standing by the Supreme Court’s decision in Food & Drug Admin. v. Alliance for Hippocratic Medicine. The court also found that the plaintiffs did not establish associational standing, as they did not identify any member facing a real and immediate threat of future injury from the patent cover language. The court concluded that amendment of the complaint would be futile, as the foundational deficiencies in establishing standing could not be remedied by further allegations. The judgment of the district court was therefore affirmed. View "US INVENTOR, INC. v. SQUIRES " on Justia Law

A veteran who served in the U.S. Army from 1969 to 1972 and deployed to Vietnam sought disability benefits for post-traumatic stress disorder (PTSD) through four claims. His first claim in 1987 was denied due to his failure to attend a required examination. He filed a second claim in 1990, providing additional details, but it was denied for lack of evidence of a stressor or diagnosis. A third claim in 2000 was also denied for similar reasons. In 2007, he filed a fourth claim to reopen, providing further information about his service. During the appeal of the 2007 denial, he obtained and submitted new service department records in 2008 that supported his PTSD claim. Ultimately, the Department of Veterans Affairs (VA) awarded him benefits with an effective date corresponding to his 2007 claim to reopen.The Board of Veterans’ Appeals concluded in 2022 that reconsideration of his claim was warranted based on the new records and granted an effective date of 1990, finding he had provided sufficient information in his 1990 claim but not in his 1987 claim. The United States Court of Appeals for Veterans Claims affirmed, holding that the version of 38 C.F.R. § 3.156(c) in effect when the new records were associated with the file (the 2006 amended version) applied, rather than the prior version.The United States Court of Appeals for the Federal Circuit reviewed whether applying the 2006 regulation to the veteran’s claims was impermissibly retroactive. The court held that the regulation’s application is triggered by the VA’s receipt or association of new and relevant service department records, and since this occurred after the 2006 amendment, applying the new regulation was proper. The court affirmed the Veterans Court’s decision. View "MILLER v. COLLINS " on Justia Law

An employee of the Internal Revenue Service, who also served as trustee for her goddaughter’s trust, was terminated from her position following an investigation into her tax returns and health insurance claims. The investigation revealed that she had improperly claimed her goddaughter and goddaughter’s son as dependents for several tax years and placed them on her federal health insurance plan, despite not meeting eligibility criteria. The employee acknowledged to investigators that she knew her actions were technically illegal. Additional incidents involving misuse of her government travel card were also considered as prior discipline. The employee challenged the resulting tax liabilities in the U.S. Tax Court, ultimately settling for a reduced amount based on a stipulation between her and the IRS.An Administrative Judge of the Merit Systems Protection Board initially reversed her removal, finding in her favor. However, following a petition for review by the IRS, the full Merit Systems Protection Board reversed the judge’s decision, sustaining her removal. The Board concluded that the IRS had proven its primary reason for removal by a preponderance of the evidence, and merged another reason into it, without reaching a third reason. The Board gave evidentiary weight to the Tax Court settlement and associated documents, which had been discounted by the Administrative Judge.On appeal, the United States Court of Appeals for the Federal Circuit reviewed whether the Board’s consideration of the Tax Court settlement documents violated evidentiary principles, specifically Federal Rule of Evidence 408. The court held that the Board did not abuse its discretion in considering those materials to establish the fact of the admitted liability, and that even if there had been an evidentiary error, the petitioner failed to show harm or prejudice. The Federal Circuit affirmed the Board’s final decision sustaining the removal. View "HARRIS-CAMPBELL v. TREASURY " on Justia Law