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

This case involves a dispute between two manufacturers of dining mats for toddlers, Luv n' Care, Ltd. and Nouri E. Hakim (collectively, “LNC”), and Lindsey Laurain and Eazy-PZ, LLC (collectively, “EZPZ”). LNC filed a lawsuit against EZPZ, seeking a declaratory judgment that EZPZ’s U.S. Patent No. 9,462,903 (the “’903 patent”) is invalid, unenforceable, and not infringed. EZPZ counterclaimed, alleging infringement of the ’903 patent, among other claims. After a bench trial, the district court found that LNC failed to prove that the ’903 patent is unenforceable due to inequitable conduct, but that EZPZ was barred from obtaining relief due to its “unclean hands.” The court also granted LNC’s motion for partial summary judgment that the claims of the ’903 patent are invalid as obvious. Both parties appealed.The United States Court of Appeals for the Federal Circuit affirmed the district court’s judgment on the doctrine of unclean hands, meaning that EZPZ was barred from obtaining relief due to its misconduct during the litigation. However, the court vacated the district court’s judgment on inequitable conduct and invalidity, finding that there were genuine disputes of material fact that precluded summary judgment. The court also vacated the district court’s denial of LNC’s motion for attorney fees and costs, and remanded the case for further proceedings. View "Luv n' Care, Ltd. v. Laurain" on Justia Law

The case involves Rimco Inc., an importer and reseller of wheels, who appealed against the United States Court of International Trade's dismissal of its action for lack of subject matter jurisdiction. Rimco sought judicial review of a denied protest against the assessment of countervailing and antidumping duties by Customs and Border Protection. Rimco argued that the Court of International Trade had exclusive jurisdiction to review the denial of protests under 28 U.S.C. § 1581(a), or alternatively, residual jurisdiction under 28 U.S.C. § 1581(i).Previously, the Court of International Trade had dismissed Rimco's action, stating that it lacked jurisdiction under § 1581(a) because Customs' application of antidumping and countervailing duties was not a protestable decision. The court also found that it lacked jurisdiction under § 1581(i) because jurisdiction under § 1581(c) would have been available if Rimco had sought administrative review of Commerce’s antidumping and countervailing duties determinations.The United States Court of Appeals for the Federal Circuit affirmed the Court of International Trade's dismissal. The court held that Customs' ministerial assessment of antidumping and countervailing duties was not a protestable decision. Furthermore, the court found that jurisdiction under 28 U.S.C. § 1581(c) would have been available and not manifestly inadequate if Rimco had not failed to exhaust administrative remedies. Therefore, the Court of International Trade correctly dismissed the case for lack of subject matter jurisdiction. View "Rimco Inc. v. United States" on Justia Law

AI Visualize, Inc. accused Nuance Communications, Inc. and Mach7 Technologies, Inc. of patent infringement in the District of Delaware. The patents in question concerned the visualization of medical scans, with an emphasis on three-dimensional views via a low-bandwidth web portal. Nuance and Mach7 sought dismissal of the case on the grounds that the patents were directed to patent-ineligible subject matter under 35 U.S.C. § 101. The district court agreed, ruling that the patents were directed to an abstract idea and failed to provide an inventive step that transformed the abstract idea into patent-eligible subject matter. Consequently, AI Visualize’s case was dismissed.Prior to this, the district court had granted Nuance and Mach7's motion to dismiss AI Visualize's complaint for failing to state a claim. AI Visualize then filed an amended complaint, which Nuance and Mach7 again moved to dismiss. The district court found that the patents attempted to address prior art problems with transporting large volume visualization datasets over a standard internet connection. However, the court ruled that the focus of the claimed advance over the prior art was abstract, and AI Visualize’s arguments that the claims were directed to improvements in computer functionality were rejected.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court’s decision. The appellate court agreed that the patents in question were directed to an abstract idea and did not offer an inventive step that transformed the idea into patent-eligible subject matter. Further, the court observed that AI Visualize's amended complaint failed to provide sufficient factual allegations to support that the claims involved unconventional technology or a concrete application of the abstract idea of virtual view "creation". Thus, the dismissal of AI Visualize’s case was affirmed. View "AI Visualize, Inc. v. Nuance Communications, Inc." on Justia Law

The United States Court of Appeals for the Federal Circuit heard the appeal of Inline Plastics Corp. against Lacerta Group, LLC. Inline Plastics alleged that Lacerta infringed on several of its patents concerning tamper-resistant plastic containers and methods of making them. After a district court ruling in favor of Lacerta, Inline appealed on the grounds that the court erred in its judgment of invalidity and infringement. Lacerta cross-appealed, challenging the denial of attorney fees and the dismissal of certain patent claims Inline dropped near the end of trial.The Court of Appeals decided to affirm the district court's denial of Inline's motion for judgment as a matter of law of validity, but vacated the court's judgment of invalidity and remanded for a new trial on this issue. The court affirmed the district court's finding of non-infringement of various claims by Lacerta, but vacated the without-prejudice dismissal of Inline’s late-withdrawn claims. The court also vacated the district court's denial of Lacerta’s motion for attorney fees under § 285. Each party will bear their own costs. View "Inline Plastics Corp. v. Lacerta Group, LLC" on Justia Law

In this case, the parents of W.J., a young man with a chromosomal abnormality and autism, brought a case under the National Childhood Vaccine Injury Act of 1986 against the Secretary of Health and Human Services, claiming that the Measles, Mumps, and Rubella vaccine administered to their son had caused or significantly aggravated his health issues. They filed their petition more than 15 years after the vaccine was administered, well beyond the Act's three-year statute of limitations. The parents argued that the statute of limitations should be equitably tolled due to their son's mental incapacitation, his minority status, and the government's alleged fraudulent concealment of a connection between the vaccine and autism.The United States Court of Appeals for the Federal Circuit affirmed the decision of the United States Court of Federal Claims, which had denied the parents' petition for review and confirmed a special master’s decision to dismiss the case as untimely. The court concluded that the mental incapacitation of the son did not qualify as an "extraordinary circumstance" warranting equitable tolling because the parents, as his legal guardians, had failed to demonstrate that they were unable to file a claim on his behalf. The court also rejected the arguments for minority tolling and fraudulent concealment, finding no basis for these in the Vaccine Act or its legislative history. The court further held that the special master had not erred in raising the issue of the statute of limitations, nor in dismissing the claim for failure to state a claim upon which relief could be granted. View "W. J. v. Health and Human Services" on Justia Law

A veteran, Robert Stinson, appealed to the United States Court of Appeals for the Federal Circuit, challenging the decision made by the U.S. Court of Appeals for Veterans Claims. The lower court affirmed the Board of Veterans’ Appeals’ denial of Mr. Stinson’s request for service connection for his blastic plasmacytoid dendritic cell neoplasm, a rare and aggressive form of cancer. Mr. Stinson argued that the Veterans Court improperly found facts in the first instance when reviewing the Board’s decision and also argued that the Veterans Court incorrectly applied the doctrine of issue exhaustion.The Federal Circuit found that the Veterans Court exceeded its statutory authority by finding facts and weighing evidence in the first instance. Specifically, the Veterans Court determined that Mr. Stinson's in-service symptoms and the location of the lesion giving rise to his BPDCN diagnosis were not relevant to his claim for service connection. The Federal Circuit held that the Veterans Court's conclusion required impermissible factual determinations.The Federal Circuit vacated the decision of the Veterans Court and remanded the case. On remand, the Veterans Court was instructed to remand the case to the Board for further factual development, including whether Mr. Stinson’s in-service symptoms support a manifestation of BPDCN earlier than 2011. This decision serves as a reminder to the Veterans Court to refrain from making factual determinations in the first instance and to focus on reviewing the Board's factual determinations. View "STINSON v. MCDONOUGH " on Justia Law

The case revolves around a class-action lawsuit brought by Simon A. Soto, a retired Marine Corps member, against the United States government. The dispute concerned the application of a six-year statute of limitations under the Barring Act (31 U.S.C. § 3702) to claims for unpaid combat-related special compensation (CRSC) under 10 U.S.C. § 1413a. Soto argued that the Barring Act's limitations did not apply to CRSC claims. The United States District Court for the Southern District of Texas agreed with Soto, leading the government to appeal to the United States Court of Appeals for the Federal Circuit.The appellate court reversed the lower court's decision, ruling that the Barring Act's six-year statute of limitations applies to CRSC settlement claims. The court reasoned that the CRSC statute does not provide its own settlement mechanism, so these claims are subject to the Barring Act's settlement procedures, including its six-year statute of limitations. The court also rejected Soto's argument that the statute of limitations should be tolled due to the continuous state of war since 1990, stating that this provision only applies to service members on active duty during times of war. The case was remanded to the district court for further proceedings consistent with the appellate court's opinion. View "SOTO v. US " on Justia Law

In the case before the United States Court of Appeals for the Federal Circuit, REV, LLC ("REV"), a veteran-owned small business that provides software consulting services, appealed a decision from the United States Court of Federal Claims regarding a bid process by the Department of Veterans Affairs ("VA").REV participated in the VA's bid process for its Transformation Twenty-One Total Technology-Next Generation (“T4NG”) program, aimed at replenishing the pool of Service-Disabled Veteran Owned Small Business (SDVOSB) vendors. REV was successful in the first stage of the bid process, but was eliminated in the second stage and was not among the final awardees.REV filed a lawsuit against the VA in the Court of Federal Claims, arguing that the VA's evaluation process was arbitrary and capricious due to alleged flaws in the process, including the VA's evaluation of rival bidders' submissions. The Court of Federal Claims dismissed REV's claims, ruling that REV lacked standing to challenge the VA’s evaluation of rival bidders' submissions and the VA’s establishment of the competitive range. The court found that REV failed to show that it was prejudiced as it could not establish that it had a greater than an insubstantial chance of securing an award had certain awardees been excluded from the bid process.On appeal, the United States Court of Appeals for the Federal Circuit disagreed with the lower court's decision, holding that REV had standing to challenge the VA's evaluation of rival bidders' submissions and the VA’s establishment of the competitive range. The court reasoned that REV had shown a substantial chance that it would have been added onto the T4NG contract if not for the alleged errors, thereby satisfying the requirements for standing. The court reversed the lower court's decision and remanded the case for further proceedings. View "REV, LLC v. US " on Justia Law

In April 2008, the Department of the Navy awarded a contract to Strategic Technology Institute, Inc. (STI) to provide various aircraft engineering and support services. The contract incorporated Federal Acquisition Regulation (FAR) 52.216-7, Allowable Cost and Payment, and FAR 52.242-4, Certification of Final Indirect Costs. STI was required to submit its cost rate proposals for fiscal years 2008 and 2009 by certain deadlines. STI did not submit these proposals until 2014, upon request by the government. After receiving these proposals, the government conducted audits and found that STI's proposals included approximately $1 million in unallowable costs. The government issued a final decision, demanding payment of unallowable costs, penalties, and interests.STI appealed to the Armed Services Board of Contract Appeals, arguing that the government's claim was barred under the six-year statute of limitations under the Contract Disputes Act. The Board rejected STI’s argument and held that the statute of limitations on any government claim for disallowed costs does not begin until the contractor submits the incurred cost proposal and provides sufficient audit records.STI then appealed to the United States Court of Appeals for the Federal Circuit. The court held that the event that started the clock for the statute of limitations is the submission of STI’s cost rate proposals in September 2014, not STI’s failure to timely submit the proposals. The court held that STI's liability for receiving overpayment was not fixed until STI submitted unallowable costs in the cost proposal. Therefore, the government’s claim could not have accrued until STI submitted its cost rate proposals. The court affirmed the decision of the Board. View "STRATEGIC TECHNOLOGY INSTITUTE, INC. v. SECRETARY OF DEFENSE " on Justia Law

In this case, Nova Group/Tutor-Saliba (“NTS”) was awarded a construction contract by the United States Department of the Navy to build a new aircraft carrier maintenance pier at a naval base. The contract required NTS to demolish an old pier, design and build a replacement pier, and construct a new structure known as the Mole Quaywall, which would be designed by the government. During construction, NTS encountered unexpected subsurface soil conditions that complicated and increased the cost of the project. NTS sought additional compensation from the government alleging differing site conditions.The United States Court of Appeals for the Federal Circuit affirmed the decision of the United States Court of Federal Claims which had denied NTS's claim for additional compensation. The Court of Federal Claims found that NTS had not established a Type I differing site condition because the contract documents disclosed that NTS would encounter unpredictable subsurface conditions and possible obstructions. It also found that NTS had failed to prove a Type II differing site condition, as it had not demonstrated that any of the potential causes for hard driving were unknown or unusual in the region or materially different from comparable work. The Court of Appeals agreed with these findings and also ruled that the parol evidence rule had not been violated as NTS claimed. The Court of Appeals found that the parol evidence rule does not prevent a party from presenting evidence that a recital of fact in an integrated agreement may be untrue, and the challenged evidence was not introduced to modify any term of the contract. Therefore, the appeal by NTS was denied and the decision of the Court of Federal Claims was affirmed. View "NOVA GROUP/TUTOR-SALIBA v. US " on Justia Law