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

Landowners in Florida who own property adjacent to a former rail corridor challenged the federal government’s issuance of a Notice of Interim Trail Use (“NITU”) under the National Trails System Act Amendments of 1983. This NITU allowed the rail corridor to be converted to a recreational trail rather than being abandoned completely. The landowners asserted that when the NITU was issued, it blocked their reversionary interests from taking effect, amounting to an uncompensated taking under the Fifth Amendment. The crux of the dispute centered on whether the railroad’s original property interests, acquired through various deeds and a condemnation judgment, were fee simple estates or merely easements.The United States Court of Federal Claims reviewed the evidence, including the deeds and the condemnation judgment, and determined that the language of each deed unambiguously conveyed a fee simple interest to the railroad. For the condemnation judgment, the court found the language ambiguous but, after consulting extrinsic evidence from the condemnation proceeding, also concluded it conveyed fee simple title. On this basis, the Claims Court held that no reversionary interest remained with the landowners, and thus no taking had occurred. The court granted summary judgment for the government.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the Claims Court’s summary judgment de novo. It agreed with the lower court’s interpretation of Florida law, finding that the relevant deeds and condemnation judgment conveyed fee simple title to the railroad. The court explained that, where the language of a deed is unambiguous, it must be enforced as written, and extrinsic evidence is only considered if ambiguity exists. The Federal Circuit affirmed the Claims Court’s judgment, holding that the landowners did not retain a reversionary interest and that the issuance of the NITU did not constitute a compensable taking. View "BARRON v. US " on Justia Law

Valtrus Innovations Ltd. owns a patent that describes methods and computer-readable memory for merging search-result lists from multiple search engines. Google LLC sought inter partes review of this patent before the United States Patent and Trademark Office’s Patent Trial and Appeal Board, arguing that the claims were unpatentable as obvious in view of several prior art references, most notably a patent known as Bushee. Bushee was filed approximately five weeks before Valtrus’s patent application, making its status as prior art contingent on whether Valtrus could establish an earlier invention date.The Patent Trial and Appeal Board reviewed Google’s challenges and Valtrus’s response that its inventors had conceived of the invention before Bushee’s filing date and exercised continuous diligence in reducing the invention to practice. The Board credited testimony from a co-inventor, supported by invention disclosure documents and metadata generated by Microsoft Word, as sufficient corroboration of the claimed earlier conception date. It further found that the inventors demonstrated reasonable diligence from just before Bushee’s filing date until the patent application was filed. As a result, the Board determined that Bushee was not prior art under pre-AIA 35 U.S.C. § 102(e) and that Google had not established unpatentability for any of the patent’s claims.Google appealed to the United States Court of Appeals for the Federal Circuit, arguing that the corroborating evidence for conception was legally insufficient and that the Board lacked substantial evidence for the diligence finding. The Federal Circuit found that metadata from Microsoft Word can serve as independent corroboration and that the Board’s findings on conception and diligence were supported by substantial evidence. The court therefore affirmed the Board’s decision, holding that Google did not prove any of the challenged claims unpatentable. View "GOOGLE LLC v. VALTRUS INNOVATIONS LTD. " on Justia Law

Satius Holding, LLC brought a lawsuit against Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., alleging infringement of claims 1, 11, and 18 of its U.S. Patent No. 6,711,385. The patent concerns a communications apparatus with a coupler designed to match impedances between air and a wireless transmitter/receiver. A central issue was whether the patent's claims, which include transmitting electric or electromagnetic signals over air, are valid given that transmitting electric signals over air is scientifically impossible.The United States District Court for the District of Delaware initially stayed the case pending reexamination by the U.S. Patent and Trademark Office, which rejected independent claim 1 but upheld dependent claims 11 and 18. After the stay was lifted, the District Court conducted claim construction and found claims 1, 11, and 18 to be indefinite, entering a final judgment of invalidity for those claims. Satius appealed this judgment to the United States Court of Appeals for the Federal Circuit.The United States Court of Appeals for the Federal Circuit reviewed the District Court’s findings de novo. It determined that, although transmitting electric signals over air is impossible, the claims were not indefinite because their scope was clear to skilled artisans. However, the court concluded that the claims failed the enablement requirement under 35 U.S.C. § 112(a), as the patent specification did not enable the full scope of the invention, including the scientifically impossible embodiments. The Federal Circuit affirmed the District Court’s final judgment of invalidity, holding that claims 1, 11, and 18 are invalid for lack of enablement, and awarded costs to Samsung. View "SATIUS HOLDING, LLC v. SAMSUNG ELECTRONICS CO., LTD. " on Justia Law

ParkerVision, Inc. and Qualcomm Incorporated have been engaged in patent litigation for over a decade, primarily involving technology related to the conversion of electromagnetic signals in wireless devices. In 2014, ParkerVision brought suit in the United States District Court for the Middle District of Florida, alleging Qualcomm infringed two patents: one containing claims directed to down-conversion (receiver claims) and up-conversion (transmitter claims) of signals. The receiver claims in both patents were similar to claims previously litigated between the parties, while the transmitter claims were distinct.The district court initially granted summary judgment of non-infringement for both receiver and transmitter claims. ParkerVision appealed, and the United States Court of Appeals for the Federal Circuit vacated the summary judgment, remanding for further proceedings, including proper claim construction and reconsideration of expert testimony. On remand, after claim construction, the parties stipulated that Qualcomm’s products did not infringe the receiver claims. The district court granted partial summary judgment of non-infringement as to these receiver claims and, at ParkerVision’s request, entered a “final judgment” under Federal Rule of Civil Procedure 54(b), severing and staying the transmitter claims pending appeal.Upon review, the United States Court of Appeals for the Federal Circuit found that it lacked jurisdiction because the district court’s Rule 54(b) judgment was not final; it resolved only some claims within a single patent cause of action, while other claims of the same patent remained unresolved. The court clarified that patent infringement constitutes a single cause of action per patent, not per patent claim, and refused to exercise jurisdiction over the appeal. The court also denied ParkerVision’s request for reassignment to a different judge, finding no grounds under Eleventh Circuit law. The appeal was dismissed, and each party was ordered to bear its own costs. View "PARKERVISION, INC. v. QUALCOMM INCORPORATED " on Justia Law

Epic Tech, LLC holds a patent for an electronic sweepstakes system and sued Pen-Tech Associates, Inc. for infringing several claims of that patent. Prior to the lawsuit, the United States Patent and Trademark Office (PTO) had issued multiple office actions rejecting claims in related patent applications, citing unpatentability under § 101 after the Supreme Court’s decision in Alice Corp. Pty. Ltd. v. CLS Bank International. Epic Tech abandoned those related applications. Pen-Tech counterclaimed for a declaration that the asserted claims were invalid under § 101, referencing PTO rejections and a district court decision in another case, Epic Tech, LLC v. Fusion Skill, Inc., which had held claims in a related patent ineligible.The United States District Court for the Northern District of Georgia granted summary judgment for Pen-Tech, declaring the asserted claims invalid under § 101, and denied Epic Tech’s cross-motion for summary judgment. Before this ruling, Pen-Tech filed motions for Rule 11 sanctions and for attorneys’ fees and costs under several statutes and the court’s inherent authority, arguing that Epic Tech and its counsel should have known the claims were likely invalid and that the lawsuit was frivolous. The district court denied these motions, finding that neither Epic Tech nor its counsel acted unreasonably or frivolously, and that the case was not exceptional nor litigated in an unreasonable or vexatious manner.The United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of sanctions and fees. It held that the district court’s order lacked sufficient explanation to permit meaningful appellate review, particularly regarding Pen-Tech’s theory that Epic Tech was on notice of potential invalidity. The Federal Circuit vacated the district court’s denial of sanctions and fees and remanded for further proceedings, without deciding whether Pen-Tech was ultimately entitled to sanctions or fees. View "EPIC TECH, LLC v. PEN-TECH ASSOCIATES, INC. " on Justia Law

A federal employee serving as a Presidential Innovation Fellow at the Department of Veterans Affairs (VA) was assigned to work on an artificial intelligence tool intended to reduce the processing time for veterans’ disability benefits claims. After reviewing the performance of the tool (CAAPI), the employee determined and communicated to agency leadership that, contrary to the agency’s public claims, the tool was producing inaccurate predictions and actually increasing the average processing time for claims. These findings were shared internally in March 2021, discussed in a blog post in April 2021 (approved and published by the VA), and elevated to higher-level management in May 2021. Despite the disclosures, the agency continued to use the tool with minor modifications, and eventually, the employee’s contract was not renewed, and he was terminated from his position.After filing a complaint with the Office of Special Counsel, the employee brought an individual right of action appeal before the Merit Systems Protection Board (the Board), alleging that his removal was in retaliation for whistleblowing. The VA moved to dismiss for lack of jurisdiction. The Board’s administrative judge, and later the full Board, concluded that the employee had not made nonfrivolous allegations that his disclosures were protected under the Whistleblower Protection Act, finding he lacked a reasonable belief that his disclosures evidenced gross mismanagement or waste.Upon review, the United States Court of Appeals for the Federal Circuit held that the employee had sufficiently raised nonfrivolous allegations that his communications constituted protected disclosures of gross mismanagement under 5 U.S.C. § 2302(b)(8). The court found the employee’s allegations plausible and sufficiently specific to establish jurisdiction for his claim before the Board. The Federal Circuit reversed the Board’s dismissal and remanded the case for further proceedings. Costs were awarded to the petitioner. View "OGUNTADE v. MSPB " on Justia Law

A group of domestic producers and a union petitioned the Department of Commerce to investigate whether steel pipes imported from Argentina were being sold in the United States at less than fair value. The petitioners supplied production data and estimates to demonstrate that their petition met statutory thresholds for industry support, using 2020 shipment figures as a proxy for domestic production. Tenaris Bay City, Inc., a major domestic producer with ties to foreign producers, opposed the petition, arguing that the industry support calculations were unreliable, particularly due to potential double counting of pipes both produced and finished domestically.After receiving comments from Tenaris, Commerce determined that the petition met the statutory requirements for industry support and initiated an antidumping investigation. Tenaris challenged this determination in the United States Court of International Trade (CIT), which remanded the issue to Commerce for further explanation specifically regarding potential double counting in the industry support calculations. On remand, Commerce found no evidence of double counting and addressed concerns about particular companies flagged by Tenaris. The CIT subsequently affirmed Commerce’s remand results, concluding the agency’s calculations were reasonable and supported by substantial evidence, and found that Tenaris’s new arguments concerning undercounting and overcounting were unexhausted because they were not timely raised during the administrative process.The United States Court of Appeals for the Federal Circuit reviewed the CIT’s decision de novo and applied a deferential standard to Commerce’s findings, overturning only if unsupported by substantial evidence or not in accordance with law. The court affirmed the CIT, holding that Commerce’s determination of industry support was reasonable and supported by the record, that Tenaris’s concerns about double counting were unsubstantiated, and that the CIT did not abuse its discretion in finding Tenaris’s additional arguments unexhausted. The CIT’s decision was affirmed. View "TENARIS BAY CITY, INC. v. US " on Justia Law

Island Creek Associates, LLC was awarded a multiple award contract (MAC) known as SeaPort-NxG by the United States Navy, alongside two other companies, Don Selvy Enterprises, Inc. (DSE) and Precise Systems Inc., each receiving contracts on identical terms. In 2022, DSE and Precise formed a joint venture, Secise, under the Small Business Administration’s Mentor-Protégé Program (MPP). In 2024, the Navy issued a modification to the SeaPort-NxG MAC, allowing MPP joint ventures, as well as their mentor and protégé members, to each hold a separate MAC, creating an exception to the previous “One Prime Contract Per Company” rule. Following this modification and the issuance of a task order to Secise, Island Creek filed a five-count complaint in the United States Court of Federal Claims, raising challenges to the contract modification, its implementation, and an alleged organizational conflict of interest involving a Navy contracting official and a Precise employee.After Island Creek’s complaint, the Navy took corrective action by rescinding the challenged portions of the contract modification, thereby reverting to the original rules. The Navy then moved to dismiss the complaint, arguing that the corrective action mooted four counts and that the remaining count was barred by statutory restrictions. The United States Court of Federal Claims dismissed the complaint, holding that Island Creek lacked statutory standing as an “interested party” under 28 U.S.C. § 1491(b)(1), but did not rule on mootness or the application of the Federal Acquisition Streamlining Act (FASA).On appeal, the United States Court of Appeals for the Federal Circuit affirmed the dismissal, but on alternative grounds. The appellate court held that Counts I–III and V were moot due to the Navy’s corrective action, which eradicated the effects of the challenged modification. It further held that Count IV was barred under the FASA’s task order protest provision, 10 U.S.C. § 3406(f), and Island Creek lacked statutory standing to challenge Precise’s award. The judgment of the Court of Federal Claims was affirmed. View "ISLAND CREEK ASSOCIATES, LLC v. US " on Justia Law

NCS Multistage Inc. sued Nine Energy Service, Inc. in the United States District Court for the Western District of Texas, alleging that Nine’s BreakThru Casing Flotation Device infringed various claims of U.S. Patent No. 10,465,445. The patent concerns a float tool for use in oil and gas wellbores, specifically a tool design to reduce friction encountered when running casing to great depths. Central to the dispute were the meanings of the claim terms “internal diameter” and “casing string,” as well as whether certain prior art sales and disclosures anticipated the patent.The district court construed “internal diameter” to refer both to an inner surface and a measured diameter, and construed “casing string” as pipe customarily having an outer diameter of at least 4.5 inches. Following trial, a jury found in favor of NCS on infringement and no invalidity, and the district court entered judgment accordingly, including an award of damages. Nine appealed, challenging the claim constructions, the exclusion of certain prior art, and evidentiary rulings regarding discovery disclosures.The United States Court of Appeals for the Federal Circuit held that the district court erred in its constructions of “internal diameter” and “casing string.” The Federal Circuit determined that “internal diameter” means a measured diameter, not also an inner surface, and that “casing string” should not be limited by a specific size. The appellate court further ruled that, under the controlling law, a private sale of a device does not constitute a public disclosure for prior art purposes, making certain prior art relevant. The court vacated the district court’s judgments of infringement, no invalidity, and damages, and remanded for a new trial with instructions consistent with its opinion. Costs were awarded to Nine. View "NCS MULTISTAGE INC. v. NINE ENERGY SERVICE, INC. " on Justia Law

TexasLDPC Inc. held an exclusive license to several patents and copyrights relating to LDPC code technology, originally developed by Dr. Kiran Gunnam while at Texas A&M University (A&M). After attempts to commercialize and sublicense the technology failed, TexasLDPC shifted its business focus exclusively to enforcing its rights through litigation. TexasLDPC filed suit in the United States District Court for the District of Delaware against Broadcom Inc., LSI Corporation, and Avago Technologies U.S. Inc. for infringement, without joining A&M, the patent owner.The District Court for the District of Delaware dismissed the suit, holding first that TexasLDPC’s license agreement with A&M had automatically terminated when TexasLDPC ceased its business operations by focusing solely on enforcement. Second, the court found that even if the agreement had not terminated, TexasLDPC could not proceed without joining A&M, as the agreement did not convey “all substantial rights” in the patents and copyrights. The court also determined A&M was a necessary party under Federal Rule of Civil Procedure 19(a) due to its interests and sovereign immunity, and dismissed the federal claims.The United States Court of Appeals for the Federal Circuit reviewed the case. It held that TexasLDPC’s exclusive license agreement had not terminated, as the contract contemplated enforcement as a legitimate business operation. The court also determined that the agreement conveyed “all substantial rights” in the asserted patents to TexasLDPC, enabling TexasLDPC to sue for infringement in its own name without joining A&M. Furthermore, A&M was not a necessary party under Rule 19(a). The Federal Circuit reversed the district court’s dismissal of the action. View "TEXASLDPC INC. v. BROADCOM INC. " on Justia Law