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

After a jury found willful patent violation, the district court entered an injunction ordering the defendant to stop making, using, and offering infringing television broadcast receivers (infringement provision) and to disable the DVR functionality in existing receivers (disablement provision). The Federal Circuit remanded, noting that the injunction would be in effect after its decision. The district court found the defendant in contempt. The Federal Circuit vacated in part, first rejecting the "two-step" process for evaluating contempt of patent injunctions. A district court, familiar with underlying parties and issues, has broad discretion in deciding to hold contempt proceedings. The court vacated the holding of contempt of the infringement provision and, in part, the damages awarded for continued infringement and remanded. The defendant's diligence and good faith efforts are not a defense to contempt, but the district court applied the wrong test. Proper analysis requires focus on the differences between the features relied upon to establish infringement and the modified features of the newly accused products. The court affirmed the finding of contempt of the disablement provision and related sanctions, rejecting claims of vagueness and overbreadth.

The owner of patents for computer modems and methods of identifying modems licensed the patents to Rockwell; a related agreement gave Rockwell sub-licensing rights. Rockwell reorganized and assigned its rights. The patent owner acknowledged the assignment. Defendants obtain modem chips from a "spin off" of the companies formed in the Rockwell reorganization. The patent owner sued for infringement. The district court held that the defendants are licensed and entered summary judgment that certain patents are invalid. The Federal Circuit reversed in part, first holding that the assignment was within Rockwell's sub-licensing rights without further consent. Two patent claims were invalid for indefiniteness, but there was a material issue of fact on whether two others were invalid for failure to disclose necessary algorithms.

In 2000 the applicant obtained a patent for an âalternator pulleyâ that uses a one-way clutch to improve the power generation efficiency of an automobileâs alternator. Two years later, the applicant filed a reissue application to add a single dependent claim, narrower than the entire patent. The application was denied on the ground that the specified error was not subject to correction on reissue because the broadest scope of the patent would remain the same. The Board of Patent Appeals affirmed. The Federal Circuit reversed and remanded. Section 251, provides for reissue: "Whenever any patent is, through error without any deceptive intention, deemed wholly or partly inoperative or invalid, by reason of a defective specification or drawing, or by reason of the patentee claiming more or less than he had a right to claim in the patent." The section authorizes reissue to add the dependent claim; its omission could render a patent partially inoperative by failing to protect the disclosed invention to the fullest extent permitted by law.

McKesson holds a patent on an electronic means of communication between doctors and patients and sued Epic, which licenses software to medical providers, for infringement. The district court entered summary judgment for Epic. The Federal Circuit affirmed. McKesson failed to demonstrate that a single party directly infringes the patent and could not succeed on its claim of indirect infringement. Customers to whom Epic licenses software neither directly perform the âinitiating a communicationâ step nor exercise control or direction over another who performs this step; no single party infringes the entire method claimed by the patent. Expanding the rules governing direct infringement to reach independent conduct of multiple actors would subvert the statutory scheme for indirect infringement.