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

The United States Department of Commerce issued a request for proposals seeking enterprise-wide information technology services. After evaluating numerous proposals, the agency announced fifteen presumptive contract awardees. CAN Softtech, Inc. (CSI) and other unsuccessful offerors challenged the awards, alleging flaws in the evaluation process. The agency responded by reevaluating the proposals multiple times, making adjustments to the technical evaluation team, and ultimately reissuing awards to the same fifteen companies. Each time, CSI and others filed new or amended bid protests, contending that the agency’s corrective actions and reevaluations were improper.The United States Court of Federal Claims initially found the agency’s evaluation of CSI’s proposal arbitrary and capricious and enjoined performance of the contracts pending reevaluation. After further corrective action by the agency, including terminating awards and issuing new evaluations, the trial court determined that the agency’s final evaluation and contract awards were rational and supported by the record. The court considered the agency’s process for reevaluation and corrective action to have satisfied procedural requirements, and rejected CSI’s argument that the agency needed to seek voluntary remand before taking corrective action.The United States Court of Appeals for the Federal Circuit reviewed the trial court’s judgment de novo. The court held that administrative agencies possess inherent authority to terminate contract awards and take unilateral corrective action in response to bid protests, so long as they act within statutory and procedural bounds and avoid arbitrary or capricious conduct. The court also determined that the agency’s actions in this case did not violate the Administrative Procedure Act and were not arbitrary, capricious, or an abuse of discretion. The Federal Circuit affirmed the trial court’s denial of CSI’s bid protest. View "SYNEREN TECHNOLOGIES CORP. v. US " on Justia Law

A veteran who served in the U.S. Navy sought service-connected disability benefits for several medical conditions, including asthma, chronic obstructive pulmonary disease (COPD), gastroesophageal reflux disease (GERD), and an enlarged prostate. He claimed that GERD and prostate issues were secondary to COPD, which he alleged was caused by exposure to lead paint during his military service. The veteran submitted medical articles and sworn statements supporting the connection between lead exposure and these conditions in February 2022 during an appeal for asthma and COPD. When he later appealed the denial of benefits for GERD and prostate conditions, he attached an addendum to his Notice of Disagreement (NOD) directing the Board of Veterans’ Appeals to consider the previously submitted evidence.After the regional office denied his claim, the veteran sought higher-level review, which was also denied. He then appealed to the Board, selecting an appeal track that allowed submission of additional evidence without a hearing. The Board denied his appeal, stating that no “new and relevant” evidence had been presented and refusing to consider the February 2022 evidence because it had been submitted before the NOD for the current claim. The Board reasoned that evidence must be submitted anew with each NOD to be considered. The veteran appealed to the United States Court of Appeals for Veterans Claims, which affirmed the Board’s decision, relying on Cook v. McDonough to hold that evidence submitted between the agency decision and the NOD was excluded from consideration.The United States Court of Appeals for the Federal Circuit reviewed the statutory interpretation de novo and held that the veteran satisfied the evidentiary submission requirement by clearly and timely referencing the prior submission in his NOD addendum. The court reversed the Veterans Court's decision, concluding that the Board must consider the evidence previously submitted and clearly incorporated by reference with the NOD. View "CASH v. COLLINS " on Justia Law

David Hamill served in the U.S. Marine Corps from 2009 to 2013 and was discharged under “Other Than Honorable” conditions. After his discharge, he sought disability compensation for PTSD and other conditions, but the Department of Veterans Affairs (VA) denied his application in 2014, citing that his discharge status barred him from most benefits. He did not appeal. In 2017 and again in 2021, Hamill filed new claims for disability benefits, which the VA interpreted as attempts to reopen his character of discharge determination. The VA ultimately granted service connection for PTSD in 2021, but did not address his discharge status, leaving Hamill without an appealable decision on that issue. Hamill’s attorney later requested an adjudication of his discharge characterization, but the VA replied that he should seek a change through the Service Department.Hamill then petitioned the United States Court of Appeals for Veterans Claims for a writ of mandamus to compel the VA to adjudicate his character of discharge claim. The Secretary moved to dismiss the petition as moot after the VA sent a letter in February 2023 explicitly finding no new and material evidence to reopen the discharge determination. Hamill also requested class certification, arguing the petition was not moot due to certain exceptions. A divided panel of the Veterans Court dismissed Hamill’s petition, concluding it was moot based on the implicit denial doctrine, which held that the 2021 VA decision implicitly denied his claim.The United States Court of Appeals for the Federal Circuit reviewed the case and held that under the Appeals Modernization Act (AMA), the VA can no longer implicitly deny claims; decisions must explicitly identify adjudicated issues. The court vacated the Veterans Court’s order dismissing Hamill’s petition and remanded the case for further proceedings, including consideration of mootness exceptions. Costs were awarded to Hamill. View "HAMILL v. COLLINS " on Justia Law

Over three hundred restaurants and businesses applied for grants from the Restaurant Revitalization Fund (RRF), a program established by Congress in response to the COVID-19 pandemic and administered by the Small Business Administration (SBA). The plaintiffs submitted their applications on the first day the portal opened, but did not receive grants before the RRF funds were exhausted. They alleged that the SBA improperly awarded grants to later applicants instead of following the statutory requirement to award grants in the order applications were received.The United States Court of Federal Claims considered the plaintiffs’ complaint seeking damages equivalent to the unpaid grants. The Government moved to dismiss the case for lack of jurisdiction under the Tucker Act and for failure to state a claim, arguing that the RRF statute did not mandate payment and that Congress imposed a cap on liability. The Court of Federal Claims denied the motion, holding that the RRF statute’s language was money-mandating, thus conferring jurisdiction under the Tucker Act, and that there was no clear statutory cap limiting the Government’s liability for the grants. The court certified its decision for interlocutory appeal.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the lower court’s decision. The appellate court held that the RRF statute was money-mandating due to its mandatory “shall award” language and the retrospective nature of the grant calculation. The court further determined that the statutory appropriation language was ambiguous and did not impose a clear cap limiting the Government’s liability. As a result, the plaintiffs’ claims fell within Tucker Act jurisdiction, and they had sufficiently stated a claim for relief. The decision of the Court of Federal Claims was affirmed. View "112 GENESEE STREET, LLC v. US " on Justia Law

In this case, the central issue arose during a countervailing duty investigation into phosphate fertilizers imported from Morocco and Russia. The International Trade Commission (Commission) collected information through questionnaires sent to various parties, including domestic and foreign producers. The Commission’s longstanding practice was to automatically designate all questionnaire responses as confidential, regardless of whether the submitting party requested confidentiality or whether the information would qualify for such treatment under the relevant statute. This led to heavy redactions in the administrative record when the investigation was challenged in court.A Moroccan producer, OCP S.A., sought review of the Commission’s injury determination in the United States Court of International Trade (CIT). The CIT initially remanded the injury determination due to insufficient evidentiary support. When the remand record again included substantial redactions, the CIT held a hearing to scrutinize the Commission’s confidentiality designations. After reviewing arguments from the Commission and affected parties, the CIT concluded that the Commission’s practice of automatically treating all questionnaire responses as confidential was unauthorized by law. The CIT found that much of the redacted information was either publicly available, generalized, or outdated, and thus not entitled to confidential treatment, with only a small portion warranting protection.The United States Court of Appeals for the Federal Circuit reviewed the CIT’s Confidentiality Opinion and Order. The Federal Circuit held that the governing statute does not abrogate the common law right of public access to judicial records and that the Commission’s blanket confidentiality rule conflicts with statutory requirements, which demand public disclosure of non-confidential information and proper justification for confidentiality. The Federal Circuit affirmed the CIT’s order that required the Commission to comply with statutory standards for confidentiality and to cease automatic confidential designation of questionnaire responses. View "In re United States" on Justia Law

In a dispute concerning antidumping and countervailing duties on mattresses imported from several countries, the U.S. International Trade Commission determined that domestic industry suffered material injury from imports sold at less than fair value and from subsidized imports. The Commission treated certain information submitted in response to its questionnaires as confidential. After the Court of International Trade issued a public opinion sustaining the Commission’s injury determination, it did not redact information the Commission had deemed confidential. The Commission requested retraction of the public opinion and sought redactions for specific company names and numerical data, arguing these deserved confidential treatment.The parties jointly moved for redaction, relying on the Commission’s practice of treating questionnaire data as confidential and citing statutory provisions. The Court of International Trade denied the motion, reasoning that the information was either publicly available or not linked to specific entities, and that some claims of confidentiality had been waived due to procedural oversight. The court also emphasized the common law right of access and transparency, but did not specifically address the statutory authority for disclosure.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the denial of the joint motion. The court found the case moot because the allegedly confidential information had already been publicly disclosed more than two years earlier, rendering any relief unavailable. The Federal Circuit held that the “capable of repetition, yet evading review” exception to mootness did not apply, as the companion case decided that day resolved the same confidentiality issues. Therefore, the appeal was dismissed, and no costs were awarded. View "In re United States" on Justia Law

Range of Motion Products, LLC owns a design patent for a body massaging apparatus, which is embodied in its product, the Rolflex. Armaid Company Inc. manufactures the Armaid2, an accused product in this suit, as well as an earlier version, the Armaid1, which was covered by a utility patent. RoM alleged that the Armaid2 infringed its design patent. Previously, RoM had filed a similar suit against Armaid in the same court, but that case was dismissed without prejudice following the denial of a preliminary injunction.In the subsequent action, the United States District Court for the District of Maine construed the design patent, carefully distinguishing between functional and ornamental aspects of the claimed design. The court found that many features, notably the shape of the arms and the base, were primarily functional, narrowing the scope of the claimed design. Upon reviewing the evidence, the district court concluded that no reasonable jury could find the design of the Armaid2 substantially similar to the patented design, and granted summary judgment of non-infringement in favor of Armaid.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s claim construction de novo and its grant of summary judgment under the First Circuit’s de novo standard. The Federal Circuit affirmed the district court’s judgment, holding that the district court did not err in identifying the functional versus ornamental aspects of the claimed design, and finding that the designs were plainly dissimilar when considering only the ornamental features. The court further held that, even when comparing the accused and claimed designs alongside prior art, no reasonable jury could find substantial similarity. The judgment of non-infringement was affirmed. View "RANGE OF MOTION PRODUCTS, LLC v. ARMAID COMPANY INC. " on Justia Law

A veteran sought compensation from the Department of Veterans Affairs (VA) for a neck injury, initially filing his claim in 2007. The VA denied the claim, and in 2008, the veteran, with the help of a non-attorney representative, filed a notice of disagreement (NOD) to appeal the denial. In 2012, the veteran retained an attorney, who entered into a contingency fee agreement and subsequently filed an additional claim on the veteran’s behalf for service-connected post-traumatic stress disorder (PTSD). The attorney also submitted new evidence and arguments to support both the neck injury claim and a claim for total disability based on individual unemployability (TDIU), referencing both the neck injury and PTSD.The Board of Veterans’ Appeals later found the neck injury was service connected and remanded the neck claim to the VA Regional Office for a rating decision, while referring the TDIU claim to the Regional Office, as it had not been addressed previously. The Regional Office ultimately granted past-due benefits for the neck injury, PTSD, and TDIU, but awarded attorney’s fees to the attorney only for the portion of benefits related to the neck injury—finding that the PTSD claim was not part of the appealed case under the relevant statute. The Board affirmed this determination, and the United States Court of Appeals for Veterans Claims also affirmed, concluding that the PTSD claim was not connected to the original NOD regarding the neck injury.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the case. The court held that, under 38 U.S.C. § 5904(c)(1) (2012), attorney’s fees may only be paid for services provided after an NOD is filed, and only for the “case” addressed by that NOD. The court affirmed that the PTSD claim was not part of the same case as the neck injury claim appealed in the 2008 NOD, and therefore attorney’s fees were not authorized for services related to the PTSD claim. The Federal Circuit affirmed the decision of the Veterans Court. View "HOLSTEIN v. COLLINS " on Justia Law

The dispute centered on technology for streaming media over networks, specifically a method described in a now-expired patent for reducing latency and improving stream quality using intermediate “helper servers” to cache and coordinate content distribution. The patent’s method claim at issue involved several steps, including receiving a request for a streaming media object from a client at a helper server, allocating a buffer at the helper server to cache part of the requested object, downloading that portion to the client while concurrently retrieving the remaining portion, and adjusting the transfer rate. The plaintiff alleged that the defendant’s system infringed this method claim by directing third-party edge servers to perform these steps.The United States District Court for the Central District of California previously granted summary judgment of noninfringement in favor of the defendant. The district court found that the accused system did not perform the required steps in the order set out in the claim and that it did not use the kind of “specialized buffer” the patent required. On a prior appeal, the United States Court of Appeals for the Federal Circuit affirmed some claim constructions, vacated the summary judgment, and remanded for further construction of the term “buffer.” On remand, the district court construed “buffer” as “short term storage associated with said requested SM object,” determined that claim 16 required both a specialized buffer and a specific order of steps, and again granted summary judgment for noninfringement.On the present appeal, the United States Court of Appeals for the Federal Circuit held that the district court erred in limiting the claim to a specialized buffer, but correctly construed the claim to require the first two steps to be performed in sequence. Because the accused system did not perform the steps in this required order, the Federal Circuit affirmed the district court’s judgment of noninfringement. View "Sound View Innovations, LLC v. Hulu, LLC" on Justia Law

The plaintiff, owner of U.S. Patent No. 7,679,637, claimed infringement by the defendant, Google LLC, concerning a patent related to web conferencing systems. The patent describes systems that allow participants to view sessions in real time, with time-shifting capabilities so that sessions can also be viewed with delay or after completion, and at different playback rates while maintaining consistent audio quality. The asserted claims permit asynchronous review of multimedia presentations, such as going back to review one aspect while another continues live.The United States District Court for the Western District of Washington reviewed the complaint, in which the plaintiff alleged infringement of claims 2–5 and 7–9 of the patent. Google moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing the asserted claims were patent-ineligible under 35 U.S.C. § 101. The district court granted the motion to dismiss, finding the claims were directed to an abstract idea without an inventive concept that would make them patent-eligible. The court also denied the plaintiff leave to amend the complaint, citing futility.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s dismissal de novo, applying the Alice two-step test for patent eligibility. The appellate court affirmed that the claims were directed to the abstract idea of asynchronous review of presentations and did not disclose a specific technological improvement or inventive concept. The court found that conventional components and result-oriented language did not suffice for eligibility and agreed that amendment of the complaint would be futile. The Federal Circuit affirmed the district court’s dismissal of the case. Costs were awarded to Google. View "US PATENT NO. 7,679,637 LLC v. GOOGLE LLC " on Justia Law