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

The dispute centers on a patented pre-lit artificial tree owned by Willis Electric Co., Ltd., which features separable, modular trunk portions that mechanically and electrically connect to one another, enabling attached lights to illuminate automatically regardless of trunk orientation. The prior art required separate mechanical and electrical connections, but Willis’ patent integrates both functions in a single step. Willis accused Polygroup of infringing claim 15 of its patent, specifically targeting Polygroup trees with the “Quick Set” feature that establishes simultaneous mechanical and electrical connections.After Willis initiated the lawsuit in the United States District Court for the District of Minnesota, Polygroup filed multiple inter partes review petitions at the Patent Trial and Appeal Board (PTAB) challenging various claims of Willis’ patent. The PTAB upheld claim 15, and the United States Court of Appeals for the Federal Circuit affirmed that finding. The district court proceedings continued with only claim 15 at issue. Polygroup filed a Daubert motion to exclude Willis’ damages expert, which was denied. At trial, the jury found claim 15 infringed and not invalid, awarding Willis over $42 million in damages. Polygroup then moved for judgment as a matter of law (JMOL) on obviousness and a new trial on damages, but the district court denied both motions.The United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL and the motion for a new trial. The court held that substantial evidence supported the jury’s finding that a skilled artisan would not have been motivated to combine prior art with coaxial barrel connectors as claimed in claim 15, thus affirming nonobviousness. The court also held that the district court did not abuse its discretion in admitting the damages expert’s testimony, finding the methodology sufficiently reliable under Rule 702. As a result, the Federal Circuit affirmed the district court’s judgment in all respects. View "WILLIS ELECTRIC CO., LTD. v. POLYGROUP LTD." on Justia Law

This case involves a challenge to the validity of a patent owned by DivX, LLC, which claims systems and methods for streaming partly encrypted media content. DivX sued Netflix, Inc. for patent infringement, leading Netflix to petition for inter partes review (IPR) before the United States Patent and Trademark Office’s Patent Trial and Appeal Board (PTAB). Netflix argued that the patent’s claims would have been obvious in view of specific prior-art references. The dispute centered on the proper construction of a claim limitation relating to the location of "encryption information" within the system described by the patent.After the IPR was instituted, the Patent Trial and Appeal Board first issued a final written decision holding that Netflix had not shown the claims were unpatentable, basing its conclusion on issues unrelated to claim construction. Netflix appealed that decision to the United States Court of Appeals for the Federal Circuit, which vacated and remanded. On remand, the Board adopted DivX’s proposed claim construction, holding that the limitation required the encryption information itself to be located within the requested portions of the selected stream of protected video, and again found in favor of DivX. Netflix appealed again.The United States Court of Appeals for the Federal Circuit reviewed the Board’s claim construction de novo. The appellate court held that the Board erred in its construction of the disputed limitation. The correct construction, the court explained, is that only the encrypted portions of the video frames, not the encryption information, must be located within the requested portions of the selected stream. The court found that, under this construction, the asserted prior art meets the limitation. The Federal Circuit therefore reversed the Board’s claim construction, vacated its decision, and remanded for further proceedings. View "NETFLIX, INC. v. DIVX, LLC " on Justia Law

Several technology companies challenged instructions issued by the Director of the United States Patent and Trademark Office (PTO) that guided the Patent Trial and Appeal Board (Board) in deciding whether to institute inter partes review (IPR) proceedings. These instructions, known collectively as the NHK-Fintiv instructions, outlined factors for the Board to consider when parallel patent litigation was occurring in district court. The challengers argued that these instructions resulted in too many denials of IPR petitions and were contrary to law, arbitrary and capricious, and issued without the required notice-and-comment rulemaking under the Administrative Procedure Act (APA).The United States District Court for the Northern District of California initially found all challenges to the PTO’s instructions to be judicially unreviewable. On appeal, the United States Court of Appeals for the Federal Circuit previously held that while the challenges based on statutory and arbitrary-and-capricious grounds were unreviewable, the claim regarding the lack of notice-and-comment rulemaking could proceed. On remand, the district court determined that the instructions were exempt from notice-and-comment requirements because they were “general statements of policy,” not substantive or legislative rules.The United States Court of Appeals for the Federal Circuit reviewed the district court’s decision de novo. The court agreed that the Director’s instructions were general statements of policy exempt from notice-and-comment rulemaking under 5 U.S.C. § 553(b). It emphasized that there is no statutory right to IPR institution, that the instructions do not bind the Director, and that the Director retains unreviewable discretion to institute or deny IPR. The court found that none of the legal standards or precedents cited by the challengers required a different result, and it affirmed the district court’s judgment rejecting the APA-based challenge. View "APPLE INC. v. SQUIRES " on Justia Law

Two companies that manufacture activated carbon honeycombs, used in automotive emission control systems, became embroiled in a legal dispute. One company holds a patent covering certain dual-stage fuel vapor canister systems, but not honeycombs used in air-intake systems. The other company began marketing a competing honeycomb product, prompting a patent infringement lawsuit. In response, the defendant challenged the validity of the patent, argued non-infringement, and asserted counterclaims alleging antitrust violations—specifically, that the patent holder unlawfully tied licenses for the patent to the purchase of its unpatented honeycomb products.The United States District Court for the District of Delaware first granted summary judgment that the patent was invalid due to prior invention. It then denied both parties’ motions for summary judgment on the antitrust and tortious interference counterclaims, finding a factual dispute about whether the honeycomb products had substantial non-infringing uses. At trial, the jury found the patent holder liable for unlawful tying under federal antitrust law, concluding that it had conditioned patent licenses on customers buying its honeycombs, and awarded significant damages. The district court denied the patent holder’s motions for judgment as a matter of law and for a new trial, confirming the jury’s findings that the honeycombs were staple goods with substantial non-infringing uses and that the conduct was not protected by immunity doctrines.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court’s judgment. The Federal Circuit held that substantial evidence supported the jury’s findings that the honeycomb products had actual and substantial non-infringing uses, making them staple goods and removing the patent holder’s statutory defense against antitrust liability. The court also rejected the argument that the patent holder’s conduct was immunized from antitrust scrutiny, and upheld the damages award, finding no error in the district court’s rulings or the jury’s determinations. View "INGEVITY CORPORATION v. BASF CORPORATION " on Justia Law

GoTV Streaming, LLC owned three related patents that describe a system in which a server receives a content request from a wireless device, tailors the content to that device’s capabilities (such as screen size), and sends the modified content to the device for display. The patents were designed to reduce the burden of developing unique applications for each device type. Instead, the server uses generic templates and custom configurations that are then tailored to the specific device’s needs.The United States District Court for the Central District of California initially dismissed GoTV’s claims for induced infringement, holding that such claims require the defendant’s knowledge of the patents before the lawsuit. The court also denied Netflix’s motion that the patents were ineligible under 35 U.S.C. § 101, finding the claims were not directed to abstract ideas. The court later found all claims of the ’865 patent indefinite and invalid, adopted some of GoTV’s proposed claim constructions, and denied GoTV’s motions to exclude certain Netflix damages evidence. At trial, the jury found Netflix infringed only one patent and awarded GoTV $2.5 million in damages. The district court denied GoTV’s post-trial motions, including for retrial on damages and for prejudgment interest predating the complaint.The United States Court of Appeals for the Federal Circuit reviewed the case. It reversed the district court’s indefiniteness finding for the ’865 patent and adopted GoTV’s claim construction. However, it held that all asserted claims were patent-ineligible under § 101 because they were directed to the abstract idea of using a generic template tailored for a user’s device without reciting an inventive concept. The Federal Circuit reversed the district court’s judgment for GoTV, ordered judgment for Netflix, and vacated the district court’s rulings on inducement and damages evidence. View "GOTV STREAMING, LLC v. NETFLIX, INC. " 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

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

A physician brought suit against several related companies, alleging that they induced surgeons to infringe claims of three patents covering surgical techniques and tools for treating spinal deformities. These patents involve methods and devices for correcting misaligned vertebrae, including the use of “handle means” and “cross-linking members” in en bloc derotation procedures. The defendant companies manufacture derotation devices that, according to the plaintiff, infringe the asserted patents when used in certain configurations. The dispute centered on whether the accused devices contained the claimed “handle means” and whether surgeons actually used the devices in infringing ways.In the United States District Court for the Eastern District of Pennsylvania, the parties disputed the meaning of “handle means,” and the court adopted the plaintiff’s proposed construction. During the trial, the plaintiff presented testimony from two experts: one on infringement and another who conducted a survey on surgical practices. The defendants moved to exclude both experts under Daubert, challenging the reliability and relevance of their methods and opinions. Initially, the district court denied these motions, finding that the experts’ application of the court’s claim construction and survey methodology affected the weight of their testimony, not its admissibility.However, following the experts’ testimony at trial, the district court reversed its earlier decision, excluded substantial portions of both experts’ testimony as unreliable and contradictory to the court’s claim construction, and then granted judgment as a matter of law to the defendants due to the lack of admissible evidence supporting infringement.On appeal, the United States Court of Appeals for the Federal Circuit held that the district court abused its discretion in excluding the expert testimony and erred in granting judgment as a matter of law. The appellate court reversed the district court’s rulings, holding that the excluded testimony did not contradict the court’s claim construction and that any methodological concerns went to evidentiary weight, not admissibility. The case was remanded for a new trial in which both experts may testify. View "BARRY v. DEPUY SYNTHES COMPANIES " on Justia Law

Crocs, Inc. owns two U.S. trademarks covering features of its Classic Clog shoes. In June 2021, Crocs filed a complaint with the United States International Trade Commission (ITC), alleging that several respondents violated Section 337 of the Tariff Act of 1930 by importing or selling footwear that infringed or diluted Crocs’s trademarks. Crocs sought a general exclusion order (GEO) or, in the alternative, a limited exclusion order (LEO). During the investigation, some respondents were found in default for failing to participate, while others actively defended against the claims.An Administrative Law Judge conducted an evidentiary hearing for the three active respondents and, in January 2023, issued an Initial Determination finding no violation of Section 337. The judge concluded that Crocs had not shown infringement or dilution of its trademarks and had waived infringement contentions against the defaulting respondents. The Commission reviewed parts of this determination and, in September 2023, issued a final decision: it found no violation by the active respondents and determined not to apply the waiver to the defaulting respondents. For the defaulting respondents, the ITC presumed the facts in Crocs’s complaint to be true, as required by statute, and issued an LEO against them, finding no public interest factors weighed against exclusion.On appeal, Crocs challenged both the no violation finding as to active respondents and the issuance of only an LEO rather than a GEO for the defaulting respondents. The United States Court of Appeals for the Federal Circuit held that Crocs’s appeal regarding the active respondents was untimely and dismissed it. Regarding the defaulting respondents, the court affirmed the Commission’s decision to issue a limited exclusion order, finding no abuse of discretion or error in law. Thus, the appeal was dismissed in part and affirmed in part. View "CROCS, INC. v. ITC " on Justia Law