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

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

Crocs's Design Patent 789, titled “Footwear,” has a single claim for the “ornamental design for footwear.” Crocs sued Dawgs for infringement, Dawgs sought inter partes reexamination (IPE) under 35 U.S.C. 311. The district court stayed its proceedings. The examiner rejected the claim as anticipated, 35 U.S.C. 102(b). While an appeal to the Patent Trial and Appeal Board was pending, Dawgs filed for Chapter 11 bankruptcy. The bankruptcy court approved the sale of all of its assets to a new entity, Holdings, “not free and clear of any Claims Crocs . . . may hold for patent infringement occurring post-Closing Date by any person ... or any defenses Crocs may have in respect of any litigation claims that are sold.” The bankruptcy court authorized the distribution of the net sale proceeds and dismissed Dawgs’s bankruptcy case. Holdings assigned all rights, including explicitly the claims asserted by Dawgs in the infringement action and the IPE, to Mojave. Dawgs dissolved but continued to exist for limited purposes, including “prosecuting and defending suits" and "claims of any kind.”The Board declined to change the real-party-in-interest from the IPE requestor to Mojave, then reversed the examiner’s rejection of the patent’s claim. The Federal Circuit granted the motion to substitute. The assignments indicate that Mojave is Dawgs's successor-in-interest; as such, Mojave has standing. If the Board precludes substitution on the basis of a transfer in interest because of a late filing, it would defeat the important interest in having the proper party before the Board. View "Mojave Desert Holdings, LLC v. Crocs, Inc." on Justia Law

Plaintiffs are a putative class of individuals who asserted personal injury claims against Old GM, and whose successor liability claims were extinguished during bankruptcy. Plaintiffs filed suit on behalf of themselves and others similarly situated, relying on A & D Auto Sales, Inc. v. United States, 748 F.3d 1142 (Fed. Cir. 2014), to allege that the extinguishment of their claims without just compensation violated the Takings Clause of the Fifth Amendment.In regard to the claims alleging coercion of Old GM, the Federal Circuit held that the statute of limitations had run when plaintiffs filed their complaint six years after their claims accrued. However, in regard to plaintiff's claim that the government had coerced the bankruptcy court and the district court, the court held that plaintiffs' claims were not within the claims court's jurisdiction. Finally, the court need not address the question of whether plaintiffs have sufficiently alleged a loss of value of their alleged property interests. Accordingly, the court affirmed the judgment. View "Campbell v. United States" on Justia Law

Former GM and Chrysler dealers, whose franchises were terminated in the 2009 bankruptcies of those companies, sued, alleging that the terminations constituted a taking because the government required them as a condition of its providing financial assistance to the companies. The Bankruptcy Code, 11 U.S.C. 363, 365, authorizes certain sales of a debtor’s assets and provides that a bankruptcy trustee “may assume or reject any executory contract or unexpired lease of the debtor.” Debtors-in-possession in chapter 11 bankruptcies, like GM and Chrysler, generally have a trustee’s powers. The Claims Court denied motions to dismiss. In interlocutory appeals, the Federal Circuit remanded for consideration of the issues of the “regulatory” impact of the government’s “coercion” and of economic impact. While the allegations of economic loss are deficient in not sufficiently alleging that the economic value of the franchises was reduced or eliminated as a result of the government’s actions, the proper remedy is to grant to leave to amend the complaints to include the necessary allegations. View "A&D Auto Sales, Inc. v. United States" on Justia Law

The IRS assigned a taxpayer identification number to Crystal Cascades, LLC. The company changed its name to Crystal Cascades Civil, LLC (CCC), but did not notify the IRS and continued using the original number. A Nevada bank made loans to CCC and recorded trust deeds. CCC failed to pay employment taxes in 2003 and 2004. The IRS filed tax lien notices in 2004-2005, under the identification number and directed to “Crystal Cascades, LLC.” In 2005 RHB made loans to CCC. The Nevada bank initiated foreclosure. CCC filed under Chapter 11. RHB argued seniority over the tax liens. During foreclosure, RHB purchased the property. Under I.R.C. 7452(d), the IRS may redeem properties against which it has a valid tax lien. The parties negotiated for RHB to pay $100,000; the IRS released its right of redemption. The bankruptcy court concluded that the lien notices did not impart constructive notice to third parties and awarded RHB surplus sale proceeds. The Ninth Circuit Bankruptcy Appellate Panel affirmed. RHB sought return of the $100,000, asserting that the agreement was void for lack of consideration because the right of redemption was illusory. The Court of Federal Claims held that RHB failed to prove that the IRS acted in bad faith. The Federal Circuit affirmed. View "Rd. & Hwy. Bldrs., LLC v. United States" on Justia Law