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

ARRIS and SeaChange provide video-on-demand products and services. ARRIS owns the 804 patent, which discloses a media server capable of transmitting multimedia information over any network configuration in real time to a client that has requested the information, allowing a user to purchase videos that are then streamed to a device such as a television. ARRIS alleged infringement by SeaChange’s Interactive Television. A jury returned a verdict in ARRIS’s favor, finding willful infringement. The Federal Circuit affirmed the verdict and the district court’s decision to enhance the damages award. The district court then permanently enjoined SeaChange from selling products that infringe the 804 patent. SeaChange released a system that it claims is outside the scope of the 804 patent. The district court found that ARRIS failed to prove contempt by clear and convincing evidence. The Federal Circuit affirmed. View "nCUBE Corp. v. Seachange Int'l, Inc." on Justia Law

Intellect’s patents involve wireless transmission of caller identification information and disclose providing caller ID information from a message center to a personal communication device, such as a cell phone, by a wireless network and displaying the caller ID information on the cell phone’s screen. Intellect sued HTC for infringement. After a bench trial, the district court held the asserted patents unenforceable due to inequitable conduct by the inventor, Henderson, who falsely asserted that the invention had been reduced to practice. The Federal Circuit affirmed, holding that Henderson’s explanations were not credible in light of a pattern of deceit. View "Intellect Wireless, Inc. v. HTC Corp." on Justia Law

The patent concerns digital communication systems with data transceivers capable of receiving multiple, analog, high-speed, serial data signals. Once received, the analog data signal must be converted into a digital signal through a process called “sampling” that involves measuring the amplitude of the analog signal at precisely timed intervals to extract the data carried in the analog signal. The receiver needs a way to discern the proper rate at which to sample the analog signal and a means for generating a sampling signal with the appropriate frequency. When data is sent through cables over long distances, the incoming signal frequency can vary. To compensate for variances, receiver circuits adjust the sampling signal to match the frequency and phase of the incoming data signal. The district court held that Emulex infringed the patent. The Federal Circuit affirmed, holding that the patent would not have been obvious at the time of invention and that the district court properly exercised its discretion in granting a permanent injunction with a well-crafted sunset period.View "Broadcom Corp. v. Emulex Corp." on Justia Law

In 2010, Microsoft filed a complaint in the U.S. International Trade Commission, alleging that Motorola had violated the Tariff Act of 1930, 19 U.S.C. 1337, by importing mobile phones and tablets that infringe several Microsoft patents. The Commission instituted an investigation and, after an evidentiary hearing, the ALJ found that the accused Motorola products did not infringe the 054, 762, 376, or 133 patents and that Microsoft had failed to prove that the mobile devices on which it relied actually implemented those patents. The Commission upheld the ALJ’s findings, finding that Microsoft failed to prove that the Microsoft-supported products on which it relied for its domestic-industry showing actually practiced the patents. The Federal Circuit reversed in part, first affirming that Motorola does not infringe the 054 patent and that Microsoft failed to prove that a domestic industry exists for products protected by the 762 and 376 patents. With respect to the 133 patent the Commission relied on incorrect claim constructions in finding no infringement, the only basis for its finding no violation, for the main group of accused products. The court affirmed the noninfringement finding for the accused alternative design. View "Microsoft Corp. v. Int'l Trade Comm'n" on Justia Law

TecSec’s 702, 452, and 781 Patents derive from a common parent application and disclose a system and a method for providing security in a data network by nesting encrypted objects into other objects which are also encrypted, allowing a system to employ different security levels to restrict access to specific compartments of data. The district court found no infringement. The Federal Circuit reversed in part, holding that the court correctly construed the term “multi-level multimedia security,” but incorrectly limited the encrypted data to objects in multimedia form. The court also erred in holding that the term “digital logic means” was a means-plus-function limitation. TecSec may be able to prove infringement against every defendant except PayPal. View "TecSec, Inc. v. Int'l Bus. Mach. Corp." on Justia Law

Houston and the District of Columbia each sought to register an official seal as a trademark in connection with various governmental services, including commerce, tourism, business administration, and public utility services. The U.S. Patent and Trademark Office refused their applications, citing Section 2(b) of the Lanham Act, which prohibits registration of a proposed trademark that consists of or comprises the flag or coat of arms or other insignia of the United States, or of any state or municipality, or of any foreign nation, 15 U.S.C. 1052(b). The Trademark Trial and Appeal Board upheld the denials. The Federal Circuit affirmed, holding that the Board correctly interpreted Section 2. View "In re: City of Houston" on Justia Law

Veterans sought disability compensation for post-traumatic stress disorder (PTSD) allegedly caused by sexual assaults that occurred during service. Their service records do not reflect any reports of the alleged sexual assaults. The VA Regional Office, Board of Veterans’ Claims, and the Court of Appeals for Veterans Claims rejected the claims in part on the ground that the service records did not include reports of the alleged assaults, and because the veterans stated that the assaults were never reported to military authorities. The Federal Circuit vacated and remanded, holding that the absence of a service record documenting an unreported sexual assault is not pertinent evidence that the sexual assault did not occur; the Board and Veterans Court may not rely on failure to report an in-service sexual assault to military authorities as pertinent evidence that the sexual assault did not occur. View "AZ v. Shinseki" on Justia Law

The federal government holds, in trust for three Indian communities, certain Minnesota land acquired in the late 1800s, with federal funds appropriated for a statutorily identified group of Indians. That beneficiary group and the three present-day communities that grew on the land overlapped but diverged. Many beneficiaries were part of the communities, but many were not; the communities included many outside the beneficiary group. In 1980 Congress addressed resulting land use problems by putting the land into trust for the three communities that had long occupied them. Since then, proceeds earned from the land, including profits from gaming, have gone to the three communities. Descendants of the Indians designated in the original appropriations acts allege that they, rather than the communities, are entitled to benefits. In earlier litigation the Federal Circuit rejected a claim that the appropriations acts created a trust for the benefit of statutorily designated Indians and their descendants. On remand, the Court of Federal Claims rejected several new claims, but found the government liable on a claim for pre-1980 revenues from the lands acquired under the 1888-1890 Acts. The Federal Circuit reversed in part, finding that the descendants had no valid claim. View "Wolfchild v. United States" on Justia Law

Rexam, Valois, and MWV compete in the perfume packaging industry. Each sells spray pumps to fragrance houses such as Estee Lauder and Chanel. MWV developed an “invisible” tube that appears to disappear when immersed in liquid, enhancing the aesthetic appearance of the perfume bottle. The inventors needed a transparent material with a refractive index close to that of the perfume liquid. In 2003, Daikin, a plastics supplier, began promoting the fluoropolymer EFEP, a highly transparent fluoropolymer with a refractive index in the correct range. The inventors experimented with EFEP, but the original tubes were hazy and brittle. They tried different production techniques, including a quenching process and eventually developed the NoC® tube. In 2005, they filed patent applications and MWV began marketing the tube. Rexam obtained and analyzed a sample, obtained EFEP, and launched its invisible tube. The district court entered summary judgment of nonobviousness; denied summary judgment of indefiniteness; denied of Rexam’s motion to exclude expert testimony; and found, after trial, infringement of certain MWV patent claims. The Federal Circuit vacated the judgment of nonobviousness, but affirmed the claim constructions, denial of the motion to exclude, and findings of infringement. Rexam and Valois waived their indefiniteness arguments by failing to pursue them at trial. View "MeadWestvaco Corp. v. Rexam Beauty & Closures, Inc." on Justia Law

Sunovion owns the rights to the patent, which is directed to pharmaceutical compositions of the single-enantiomer drug eszopiclone, the active ingredient in the chiral drug marketed as a sleep medication with the brand name Lunesta®. The district court held, on summary judgment, that Dr. Reddy’s Laboratories did not infringe certain claims in that patent. The Federal Circuit reversed. Although the district court did not err in construing the claim term “essentially free” as containing less than 0.25 percent levorotatory isomer, Sunovion was entitled to a judgment of infringement as a matter of law under 35 U.S.C. 271(e)(2)(A). A generic manufacturer’s “certification” pledging not to infringe cannot override the conclusion that when a drug manufacturer seeks FDA approval to market a generic compound within the scope of a valid patent, it is an infringement as a matter of law. View "Sunovion Pharm., Inc. v. Teva Pharm. USA, Inc." on Justia Law