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

The Massachusetts Institute of Technology owns three patents related to fuel management systems for spark ignition engines, which are exclusively licensed to Ethanol Boosting Systems, LLC. These patents describe a system that uses both direct and port fuel injection to mitigate engine knock and optimize performance. The system operates with varying injection mechanisms depending on engine torque or manifold pressure, and includes a three-way catalyst to reduce emissions. The patents contain claims focusing on the interplay of injection types with engine operating ranges and the use of anti-knock agents.Previously, Ford Motor Company petitioned the Patent Trial and Appeal Board (PTAB) for inter partes review (IPR) of all three patents. The PTAB initially denied institution, largely due to a claim construction that restricted the definition of “fuel” in a manner consistent with a district court’s prior interpretation, which required the directly injected fuel to differ from the port-injected fuel and to contain an anti-knock agent other than gasoline. After the Federal Circuit, in Ethanol Boosting Sys., LLC v. Ford Motor Co., vacated the district court’s construction regarding the “different fuel” requirement (but did not address the anti-gasoline requirement), the PTAB granted Ford’s rehearing request and instituted the IPRs.On appeal from the PTAB, the United States Court of Appeals for the Federal Circuit reviewed the Board’s final written decisions, which found the relevant claims of all three patents unpatentable as obvious. The Federal Circuit rejected EBS’s arguments that the Board lacked authority to delay its rehearing decision and that the Board was bound by the non-appealed portion of the district court’s claim construction. The court affirmed the Board’s adoption of the plain and ordinary meaning of the disputed terms and found substantial evidence supporting the Board’s factual findings regarding obviousness. The holding is that the PTAB’s decisions finding all challenged claims unpatentable as obvious are affirmed. View "ETHANOL BOOSTING SYSTEMS, LLC v. FORD MOTOR COMPANY " on Justia Law

Micron Technology and its subsidiaries, along with the State of Idaho, were sued for patent infringement by Katana Silicon Technologies in the United States District Court for the Western District of Texas. The patents at issue related to technology for shrinking semiconductor devices and had expired. In response, Micron asserted a counterclaim under the Idaho Bad Faith Assertions of Patent Infringement Act, alleging that Katana had made bad faith assertions of patent infringement. Katana moved to dismiss the counterclaim, arguing that the Idaho Act was preempted by federal patent law. The case was transferred to the United States District Court for the District of Idaho, where the State of Idaho intervened to defend the statute. Separately, Micron filed suit in Idaho state court against Longhorn IP, alleging similar bad faith assertions and seeking the imposition of a bond. Longhorn removed that case to federal court and also moved to dismiss on preemption grounds.The United States District Court for the District of Idaho denied both motions to dismiss, holding that federal law did not preempt the Idaho statute. The court also imposed an $8 million bond on Longhorn and Katana pursuant to the Act, finding that there was a reasonable likelihood that a bad faith assertion of patent infringement had occurred. Katana and Longhorn appealed these decisions to the United States Court of Appeals for the Federal Circuit.The United States Court of Appeals for the Federal Circuit dismissed the appeal for lack of jurisdiction. The appellate court determined that there was no final judgment from the district court, as the only decisions made were the denial of motions to dismiss and the imposition of a bond, neither of which ended the litigation on the merits. The Federal Circuit also found that none of the exceptions for interlocutory appellate review applied, including those for injunctions, the collateral order doctrine, or mandamus, nor was pendent jurisdiction appropriate. View "Micron Technology, Inc. v. Longhorn IP LLC" on Justia Law

Wonderland Switzerland AG owns two patents related to child car seats, U.S. Patent Nos. 7,625,043 and 8,141,951. Wonderland sued Evenflo Company, Inc., alleging that five Evenflo convertible car seat models, categorized as “4-in-1” and “3-in-1” seats, infringed claims of both patents. The dispute focused on specific features of the accused car seats, such as mechanisms for attaching the seat back to the seat assembly and the structure of engaging components.A jury in the United States District Court for the District of Delaware found that both Evenflo’s 3-in-1 and 4-in-1 seats infringed claim 1 of the ’043 patent under the doctrine of equivalents and that the 4-in-1 seats also infringed claims 1 and 5 of the ’951 patent, both literally and under the doctrine of equivalents. The jury found Evenflo’s infringement of the ’043 patent was not willful. The district court denied both parties’ motions for judgment as a matter of law and for a new trial, granted a permanent injunction covering both patents, and denied Wonderland’s motion for a new trial on willful infringement.On appeal, the United States Court of Appeals for the Federal Circuit reversed the judgment that Evenflo’s 4-in-1 seats infringe claim 1 of the ’043 patent under the doctrine of equivalents, finding no substantial evidence supported the jury’s verdict on that point. The court also reversed the permanent injunction as to both patents because the injunction for the ’951 patent was not requested and the showing for irreparable harm as to the ’043 patent was insufficient. Furthermore, the court reversed the denial of a new trial on willful infringement of the ’043 patent (for the 3-in-1 seats only) due to wrongful exclusion of key evidence. The judgment was otherwise affirmed, and the case was remanded for further proceedings. View "WONDERLAND SWITZERLAND AG v. EVENFLO COMPANY, INC. " on Justia Law

A non-profit organization focused on supporting student-athletes registered a stylized mark incorporating the phrase “I AM MORE THAN AN ATHLETE. GP GAME PLAN” for use in charitable fundraising via apparel sales. Later, a media company filed six intent-to-use applications for marks containing “I AM MORE THAN AN ATHLETE” and “MORE THAN AN ATHLETE,” covering clothing and entertainment services. The non-profit opposed these applications before the Trademark Trial and Appeal Board, arguing likelihood of confusion and asserting priority based on both its registration and alleged common law rights. The media company counterclaimed, seeking cancellation of the non-profit’s registration and asserting that it had acquired priority through an assignment of common law rights from a third party who had used “MORE THAN AN ATHLETE” since at least 2012.During the Board proceeding, the non-profit failed to introduce any trial evidence to establish its common law rights or priority. The Board dismissed the opposition due to lack of evidence. As to the counterclaim, the Board found that the media company had acquired valid and enforceable common law rights in the mark through its assignment, which included the goodwill associated with the mark. The Board rejected arguments that the assignment was invalid because it occurred during litigation or was an assignment in gross, and concluded that, at least for clothing, the transfer was valid. The Board canceled the non-profit’s registration and dismissed its opposition.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the Board’s factual findings for substantial evidence and legal conclusions de novo. The court held that the Board’s decision was supported by substantial evidence and affirmed that the assignment was not in gross, did not violate statutory or regulatory prohibitions, and that the non-profit’s failure to submit evidence justified dismissal. The decision to cancel the non-profit’s registration and dismiss its opposition was affirmed. View "GAME PLAN, INC. v. UNINTERRUPTED IP, LLC " on Justia Law

IBM owns a patent concerning single sign-on (SSO) technology, which allows users to access protected resources on a second system using credentials from a first system. In simplified terms, the invention facilitates account creation on a second platform (such as a healthcare provider) using a user identifier already stored by the first platform (such as a social media website), thereby avoiding the need for users to create separate accounts for each service. The patent describes specific systems and processes for transmitting user identifiers and managing account creation in distributed environments.Ebates Performance Marketing, Inc. (Rakuten) filed petitions for inter partes review of IBM’s patent at the United States Patent and Trademark Office’s Patent Trial and Appeal Board (PTAB), asserting anticipation and obviousness based on several prior art references, especially a system disclosed in Sunada. The PTAB adopted IBM’s construction of certain claim terms but found that Sunada taught or suggested most relevant limitations. The Board held claims 1–4, 12–16, and 18–19 unpatentable, while claims 5–11, 17, and 20 were found not unpatentable because the prior art did not disclose a specific process required by those claims.IBM appealed the PTAB’s ruling to the United States Court of Appeals for the Federal Circuit, arguing that the Board’s analysis exceeded the scope of Rakuten’s petition and that its findings lacked substantial evidence. Zillow, which had joined the review, cross-appealed regarding claims found not unpatentable. The Federal Circuit held that the Board’s analysis was consistent with the petition and supported by substantial evidence. It found the Board’s distinction between similar claims reasonable and affirmed both the appeal and cross-appeal, leaving the PTAB’s patentability determinations undisturbed. View "IBM v. ZILLOW GROUP, INC. " on Justia Law

Bayou Grande Coffee Roasting Company applied to register the trademark KAHWA for use in connection with cafés and coffee shops. The trademark examiner refused registration on the grounds that KAHWA was generic or merely descriptive, relying on two meanings: one, that KAHWA allegedly means “coffee” in Arabic, and two, that it refers to a specific type of Kashmiri green tea. The examiner also invoked the doctrine of foreign equivalents, which tests foreign words for genericness and descriptiveness by translating them into English.After Bayou responded, arguing that KAHWA does not mean coffee in Arabic and that the Kashmiri green tea meaning is not relevant to American cafés and coffee shops, the examiner maintained refusals on both grounds. Bayou requested reconsideration, and the examiner continued to refuse registration, reiterating both rationales. Bayou appealed to the United States Patent and Trademark Office’s Trademark Trial and Appeal Board, which affirmed the refusal solely on the basis of the Kashmiri green tea meaning, without addressing the Arabic coffee meaning.On further appeal to the United States Court of Appeals for the Federal Circuit, Bayou contended that the Board’s findings of genericness and mere descriptiveness were unsupported by substantial evidence, and also challenged reliance on the doctrine of foreign equivalents. The Federal Circuit held that there was no evidence showing any café or coffee shop in the United States has ever sold kahwa, and thus KAHWA cannot be generic or merely descriptive for cafés and coffee shops. The court also concluded that the doctrine of foreign equivalents does not apply because KAHWA has a well-established English meaning as Kashmiri green tea. The Federal Circuit reversed the Board’s decision, holding that KAHWA is registrable for the identified services. View "In Re BAYOU GRANDE COFFEE ROASTING CO. " on Justia Law

The plaintiffs, Coda Development s.r.o., Coda Innovations s.r.o., and Frantisek Hrabal, brought claims against Goodyear Tire & Rubber Company and Robert Benedict, alleging misappropriation of trade secrets related to self-inflating tire technology and seeking correction of inventorship on a Goodyear patent. Coda claimed that Goodyear misappropriated five specific trade secrets involving technical solutions, testing data, and optimal component placement for this technology. The alleged misappropriation stemmed from communications and interactions between the parties concerning this technology.In the United States District Court for the Northern District of Ohio, the case proceeded to a jury trial on the trade secret claims. The jury found in favor of Coda, concluding that Goodyear misappropriated five trade secrets and awarding substantial compensatory and punitive damages. Following the trial, the district court granted Goodyear’s motion for judgment as a matter of law, determining that the asserted trade secrets were either not sufficiently definite, not secret, not used by Goodyear, or not adequately conveyed to Goodyear, and thus set aside the jury’s verdict. The court also denied Coda’s claim seeking correction of inventorship on Goodyear’s patent, after considering the parties’ briefing in lieu of a bench trial.The United States Court of Appeals for the Federal Circuit reviewed the district court’s decisions. The appellate court affirmed the district court’s judgment as a matter of law, holding that no reasonable jury could have found that all elements required for trade secret misappropriation were met for any of the asserted trade secrets. The Federal Circuit also affirmed the denial of the correction of inventorship claim, concluding that Coda failed to provide evidence that would entitle it to such relief. The district court’s judgment was affirmed in all respects. View "CODA DEVELOPMENT S.R.O. v. GOODYEAR TIRE & RUBBER COMPANY" on Justia Law

Adnexus, Inc. owns a patent for a system and method of online advertising that aims to deliver targeted advertisements to users without overwhelming them with irrelevant content. Adnexus alleged that Meta Platforms, Inc.'s Lead Ads product infringed at least one claim of this patent. Specifically, Adnexus argued that Lead Ads retrieves a user profile containing delivery method preferences and other information, which matches the patent’s claim requirement. Adnexus attached detailed claim charts and a preliminary infringement analysis to its amended complaint to show how Lead Ads purportedly meets each element of the asserted claim.In the United States District Court for the Western District of Texas, Meta moved to dismiss the amended complaint, arguing that Adnexus failed to plausibly allege that Lead Ads met the claim limitation requiring retrieval of a user profile containing delivery method preferences. The district court agreed with Meta, finding that “contact information” was distinct from “delivery method preferences” and that Adnexus’s allegations were insufficient. The court dismissed the complaint with prejudice, as Adnexus had already amended its pleading once. The court also dismissed indirect and willful infringement claims, and found Adnexus estopped from asserting infringement under the doctrine of equivalents.The United States Court of Appeals for the Federal Circuit reviewed the district court’s dismissal de novo. The appellate court held that the district court erred in implicitly construing the claim term “delivery method preferences” against Adnexus, the non-moving party, without providing Adnexus an opportunity to address claim construction. The Federal Circuit found that Adnexus’s amended complaint, when taken as true and viewed in the light most favorable to Adnexus, plausibly alleged infringement of the relevant claim limitation. The Federal Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "ADNEXUS INC. v. META PLATFORMS, INC. " on Justia Law

The dispute centers on a patent for a type of cancer treatment called an antibody-drug conjugate (ADC), which combines an antibody, a cytotoxic drug, and a linker protein. The patent at issue claimed a particular kind of linker, a tetrapeptide consisting only of glycine and phenylalanine amino acids. Seagen, the patent holder, sued Daichii Sankyo and AstraZeneca, alleging that their ADC product, Enhertu, infringed claims of this patent. Notably, Enhertu contains the specific tetrapeptide sequence described in the patent. The patent’s priority was claimed from a 2004 application, though the sequence in question had not been expressly disclosed in that earlier filing.The United States District Court for the Eastern District of Texas presided over a jury trial. The jury found the asserted patent claims valid, not invalid for lack of written description or enablement, and determined that the defendants had willfully infringed. Damages exceeding $41 million were awarded to Seagen. The district court denied the defendants’ post-trial motion for judgment as a matter of law (JMOL), upholding the jury’s verdict and entering final judgment for Seagen.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the case. The appellate court held that the district court erred in denying JMOL because the original 2004 application did not provide adequate written description support for the claimed subgenus of Gly/Phe-only tetrapeptides. The Federal Circuit found that the patent specification failed to demonstrate that the inventors possessed the claimed invention as of the 2004 filing date, and that the patent was not enabled because a skilled artisan would need to engage in undue experimentation to make and use the full scope of the claimed ADCs. Accordingly, the Federal Circuit reversed the district court’s judgment, found the patent invalid, and vacated the jury’s findings of infringement and damages. View "SEAGEN INC. v. DAIICHI SANKYO COMPANY, LTD. " on Justia Law

The case involves Gesture Technology Partners, LLC, which owns U.S. Patent No. 7,933,431 related to methods and apparatus for rapid TV camera and computer-based sensing of objects and human input, usable in devices such as handhelds, cars, and video games. After Samsung Electronics requested an ex parte reexamination of the patent, the United States Patent and Trademark Office initiated proceedings. Concurrently, two inter partes review (IPR) proceedings were filed against the same patent by Unified Patents LLC and other entities, resulting in the Patent Trial and Appeal Board invalidating most claims of the patent.After the Patent Trial and Appeal Board issued final written decisions in both IPRs, Gesture Technology Partners petitioned the Patent Office to terminate the ex parte reexamination, arguing that Samsung, as a party to the IPR, was estopped under 35 U.S.C. § 315(e)(1) from maintaining further proceedings on grounds that could have been raised in the IPRs. The Patent Office denied the petition, holding that the estoppel provision did not apply to ongoing ex parte reexaminations. Subsequently, the Board affirmed the examiner’s rejection of claims 11 and 13 as anticipated by a prior patent, Liebermann. Gesture appealed these decisions.The United States Court of Appeals for the Federal Circuit reviewed the case. It held that the estoppel provision of 35 U.S.C. § 315(e)(1) does not apply to ongoing ex parte reexamination proceedings, as the requester does not “maintain” the proceeding—the Patent Office does. The court also affirmed the Board’s finding that the Liebermann patent anticipates claims 11 and 13. Furthermore, it rejected the argument that the Board lacked jurisdiction because the patent had expired, citing continued rights to past damages. The court affirmed the Board’s decision as to claims 11 and 13 and dismissed the appeal as to the previously invalidated claims. View "In Re GESTURE TECHNOLOGY PARTNERS, LLC " on Justia Law