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

This case involves Packet Intelligence LLC ("Packet") and NetScout Systems, Inc. and NetScout Systems Texas, LLC (collectively, "NetScout"). Packet had sued NetScout for patent infringement. The U.S. District Court for the Eastern District of Texas found that NetScout had willfully infringed Packet's patents and awarded Packet damages, enhanced damages for willful infringement, and an ongoing royalty. NetScout appealed this decision.In a previous appeal, the United States Court of Appeals for the Federal Circuit had reversed the district court's award of pre-suit damages and vacated the court's enhancement of that award. The court affirmed the district court's judgment in all other respects and remanded the case to the district court. On remand, the district court denied NetScout's motion to dismiss or stay the case and entered an amended final judgment. The amended judgment reduced the enhanced damages and reset the ongoing royalty rate.Meanwhile, the Patent Trial and Appeal Board ("Board") found all of the patent claims asserted by Packet in this case unpatentable as obvious. Packet appealed the Board's final written decisions. The Federal Circuit coordinated those appeals so they would be considered by the same panel deciding this appeal.The United States Court of Appeals for the Federal Circuit vacated the district court’s amended final judgment and remanded the case with instructions to dismiss the case as moot. The court held that Packet’s infringement judgment was not final before the Board’s unpatentability determinations were affirmed. Therefore, the court was compelled to order that Packet’s patent infringement claims be dismissed as moot. View "PACKET INTELLIGENCE LLC v. NETSCOUT SYSTEMS, INC. " on Justia Law

The case revolves around SnapRays, a Utah-based company that designs, markets, and sells electrical outlet covers with integrated guide lights, safety lights, motion sensor lights, and USB charging technology, and Lighting Defense Group (LDG), an Arizona-based company that owns a patent related to a cover for an electrical receptacle. LDG submitted an Amazon Patent Evaluation Express (APEX) Agreement alleging that certain SnapPower products sold on Amazon.com infringed its patent. SnapPower subsequently filed an action for declaratory judgment of noninfringement.The United States District Court for the District of Utah dismissed SnapPower's complaint for lack of personal jurisdiction over LDG. The court concluded that LDG lacked sufficient contacts with Utah for it to exercise specific personal jurisdiction. It found that LDG's allegations of infringement were directed toward Amazon in Washington, where the APEX Agreement was sent, and not at SnapPower in Utah. The court also noted that under Federal Circuit law, principles of fair play and substantial justice support a finding that LDG is not subject to specific personal jurisdiction in Utah.The United States Court of Appeals for the Federal Circuit reversed the lower court's decision. The appellate court concluded that LDG purposefully directed extra-judicial patent enforcement activities at SnapPower in Utah, thereby satisfying the requirements for specific personal jurisdiction. The court found that LDG's submission of the APEX Agreement to Amazon, which identified SnapPower's listings as allegedly infringing, was an intentional action aimed at affecting SnapPower's sales and activities in Utah. The court also rejected LDG's argument that the assertion of specific personal jurisdiction over it in Utah would be unfair and unreasonable. The case was remanded for further proceedings. View "SNAPRAYS v. LIGHTING DEFENSE GROUP " on Justia Law

The case revolves around a dispute between Jalmar Araujo and Framboise Holdings Inc. over the registration of the standard character mark #TODECACHO. Araujo filed a U.S. Trademark Application to register #TODECACHO for hair combs. Framboise opposed the registration, claiming that it would likely cause confusion with its #TODECACHO design mark, which it had been using in connection with various hair products since March 24, 2017. Framboise also had a pending trademark application for the same mark.The United States Patent and Trademark Office Trademark Trial and Appeal Board (the Board) granted Framboise an extension to submit its case in chief. Araujo opposed this extension and the late submission of a declaration by Adrian Extrakt, Director of Framboise. However, the Board granted the extension, finding that the delay was minimal and that Framboise had met the applicable good cause standard. The Board then relied on the Extrakt declaration to support Framboise's claim of prior use of the #TODECACHO design mark.The Board found that Framboise had met its burden to establish prior use by a preponderance of the evidence. It found that the Extrakt declaration alone was sufficient to prove prior use because it was clear, convincing, and uncontradicted. Having found an earlier priority date for Framboise, the Board found a likelihood of confusion between the two marks, sustained the opposition, and refused registration of Araujo’s mark.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Board's decision. The court found that the Board did not abuse its discretion in granting the extension and that the Board's finding that Framboise established prior use of the #TODECACHO design mark was supported by substantial evidence. View "ARAUJO v. FRAMBOISE HOLDINGS INC. " on Justia Law

The case involves Tony Lamonte Greene and Billie Wayne Byrd, who are incarcerated in an Oklahoma state prison. They, along with seven co-plaintiffs, filed actions in the Court of Federal Claims, arguing that their imprisonment is unlawful and seeking monetary compensation from the United States. They claim to be members of the Cherokee Nation and argue that under certain treaties between the Cherokee Nation and the United States, the State of Oklahoma lacked jurisdiction to prosecute and incarcerate them. They each seek $100 per day for unauthorized detention and more than $1,000,000 in compensatory and punitive damages.The Claims Court dismissed the plaintiffs’ actions for lack of jurisdiction. The court held that the plaintiffs failed to show that the treaties on which they relied gave rise to a personal right to monetary relief on their part in the event of a breach of the covenants relating to the exercise of civil and criminal jurisdiction within the Cherokee Nation. The court explained that claims based on treaties with Indian nations can fall within the jurisdiction of the Claims Court because they are treated as “a species of contract.” However, the court concluded that the treaties were not money-mandating.The United States Court of Appeals for the Federal Circuit affirmed the decision of the Claims Court. The court found that the treaty provisions the appellants relied upon are not money-mandating. The court also noted that the agreements addressed the respective rights of sovereignty of the two contracting parties; they did not create contract-based rights in individuals, the breach of which could give rise to monetary remedies for those individual complainants. The court concluded that the appellants’ claim does not fall within the reach of the Tucker Act, and therefore, the Claims Court lacked jurisdiction to address their demand for damages from the United States attributable to their prosecution and incarceration by the State of Oklahoma. View "GREENE v. US " on Justia Law

The case involves Benito R. Chavez, a Vietnam War veteran who sought service connection for posttraumatic stress disorder (PTSD). After being diagnosed with chronic, moderately severe PTSD, he was granted a 100 percent disability evaluation by the Department of Veterans Affairs (DVA). However, after a subsequent medical examination, his disability rating was reduced to 50 percent, and later increased to 70 percent, as it was determined that his condition did not result in total occupational impairment. Chavez disagreed with this decision and appealed to the Board of Veterans’ Appeals, which upheld the reduction.Chavez then appealed to the Court of Appeals for Veterans Claims, arguing that the Board's decision should be reversed and his 100 percent rating reinstated. The Veterans Court agreed that the Board may have improperly relied on evidence developed after the rating reduction, but instead of reversing the Board’s decision, it remanded the case back to the Board for further examination.Chavez appealed this decision to the United States Court of Appeals for the Federal Circuit, arguing that the Veterans Court should have reversed the Board’s decision rather than remanding the case. The government contended that the Federal Circuit lacked jurisdiction over Chavez's appeal. The Federal Circuit rejected the government's jurisdictional argument but affirmed the decision of the Veterans Court on the merits. The Federal Circuit held that the Veterans Court was fully entitled to remand the case to the Board for clarification, and therefore, the decision of the Veterans Court was affirmed. View "Chavez v. McDonough" on Justia Law

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