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

The patent, entitled “Slot Machine Game and System with Improved Jackpot Feature,” issued in 2006 and relates to a system of linked gaming machines through which an allegedly improved jackpot mechanism is provided to a player. Incremental jackpots are well known in the prior art, but the patent claims that prior art systems lack flexibility in both operator control and ability to tailor prizes to player preferences, through a bonus game that may appear. The district court granted summary judgment of noninfringement, explaining that the accused products require two separate actors, the casino via the gaming machine and the player, and that the lack of a single entity performing all of the steps of the asserted claims precluded direct infringement as a matter of law. The Federal Circuit affirmed the district court’s claim constructions and its ruling on direct infringement but, in light of an intervening decision, vacated and remanded the ruling on indirect infringement. View "Aristocrat Tech., Australia v. Int'l Game Tech." on Justia Law

High-efficiency DC-DC power converter systems are used to power circuitry in large computer systems and telecommunication and data communication equipment. The patents at issue involve converters with separate “isolation” and “regulation” stages and improved prior art power converter systems that used integrated converters, each performing both isolation and regulation, to step the 48 volt input down to the voltage levels required to power logic circuitry. Large computer and communication systems use multiple voltage levels for different logic circuitry housed on a single load board, and the prior art systems required a separate isolating/regulating converter for each voltage level, which took up valuable space on the load board, which could otherwise accommodate more memory and other logic circuitry. The district court entered summary judgment of infringement and awarded $95 million in lost profits plus enhanced damages for post-trial infringement, finding that the “isolation” limitations of the patents appeared in defendants’ products. The Federal Circuit affirmed. View "Synqor, Inc. Artesyn Techs., Inc." on Justia Law

In 2009, following a petition and a related investigation, the Department of Commerce issued anti-dumping orders concerning citric acid and certain citrate salts from Canada and the People's Republic of China: In the Final Scope Determination, Commerce found the portion of GCG’s merchandise consisting of citric acid from the People’s Republic of China (PRC), approximately 35 percent, within the scope of the anti-dumping duty and countervailing duty orders. The Court of International Trade sustained the determination. The Federal Circuit affirmed. Commerce’s application of the Order, assessing a duty on GCG’s product “according to the rates applicable to citric acid from both the PRC and any other country represented in the blend, based upon the quantity and value of citric acid from each country included in the blend,” evidences that Commerce’s interpretation appropriately accounts for both the physical scope of the product as well as the country of origin.View "Global Commodity Grp., LLC v. United States" on Justia Law

The patent examiner rejected all of the inventors’ pending claims in an application entitled “Enzyme-Mediated Modification of Fibrin for Tissue Engineering,” filed in 2003, relating generally to the field of tissue repair and regeneration, and more specifically to matrices containing bidomain peptides or proteins. The examiner found obviousness-type double patenting over several patents. The Board of Patent Appeals and Interferences affirmed. The Federal Circuit affirmed; tO'Mahe Board did not err in concluding that the pending claims were barred under the doctrine of obviousness-type double patenting. View "In re Hubbell" on Justia Law

Bumper Boy holds two patents on improvements to electronic animal collars; the 082 patent is a continuation-in-part of the 014 patent. Although the 082 patent contains some new matter, the asserted claims from the 082 patent are supported by the 014 patent specification. Both patents generally disclose and claim a collar having “high point surfaces” that extend the inside surface of the collar above the base of electrodes 24 toward the animal “to relieve and distribute the load caused by collar tension around the animal’s neck” and reduce discomfort. The district court construed “inside surface” as “the portion of the collar housing facing inwards towards the animal” and “electrode base” as “the portion of the electrode where it intersects the inside surface of the collar housing” and held that Radio Shack and Innotek did not infringe the patents. The Federal Circuit affirmed with respect to claim construction, but reversed with respect to the district court’s reliance on equitable estoppel. View "Radio Sys. Corp. v Lalor" on Justia Law

REAL owns the 989 patent, now expired, directed to methods for locating available real estate properties using a zoom-enabled map on a computer. Move operates and maintains multiple interactive websites that allow users to search for available real estate properties and sought a declaratory judgment that REAL’s patents were invalid and that Move’s websites did not infringe them. REAL counterclaimed, alleging that the “Search by Map” and “Search by Zip Code” functions employed by Move infringed REAL’s claimed search methodologies. In 2009, the parties stipulated to non-infringement based on the district court’s claim construction, and after judgment was entered in favor of Move, REAL appealed regarding only one claim. The Federal Circuit vacated and remanded, holding that “selecting an area” as recited in the claim means that “the user or a computer chooses an area having boundaries, not when the computer updates certain display variables to reflect the selected area.” On remand, the district court entered summary judgment for Move. The Federal Circuit again vacated, holding that while Move cannot be liable for direct infringement, the district court erred by not analyzing inducement under 35 U.S.C. 271(b). View "Move, Inc. v. Real Estate Alliance, Ltd." on Justia Law

Casitas Water District operates the Ventura River Project, which is owned by the U.S. Bureau of Reclamation and provides water to Ventura County, California, using dams, reservoirs, a canal, pump stations, and many miles of pipeline. In 1997, the National Marine Fisheries Service listed the West Coast steelhead trout as an endangered species and determined that the primary cause of its decline was loss of habitat due to water development, including impassable dams. Casitas faced liability if continued operation of the Project resulted in harm to the steelhead, 16 U.S.C. 1538(a)(1), 1540(a)–(b). In 2003, NMFS issued a biological opinion concerning operation of a fish ladder to relieve Casitas of liability. Casitas opened the Robles fish ladder, then filed suit, asserting that the biological opinion operating criteria breached its 1956 Contract with the government or amounted to uncompensated taking of Casitas’s property. The Claims Court dismissed, citing the sovereign acts doctrine. The Federal Circuit affirmed dismissal of the contract claim, but reversed dismissal of Casitas’s takings claim. The court again dismissed, holding that Casitas had failed to show that the operating criteria had thus far resulted in any reduction of water deliveries, so a takings claim was not yet ripe. The Federal Circuit affirmed. View "Casitas Mun. Water Dist. v. United States" on Justia Law

Smith was disbarred by the Tenth Circuit in 1996, followed by reciprocal disbarments by the Fifth Circuit, the U.S. District of Colorado and Northern District of Texas, and the Colorado Supreme Court. In 2007, the Tenth Circuit granted reinstatement, provided that Smith met conditions. The conditions were satisfied, and Smith was reinstated. The other courts then readmitted him to their bars, except the Colorado Supreme Court. The United States District Court for the District of Colorado then reversed itself and denied reinstatement, because Smith remained disbarred by the Colorado Supreme Court. The Tenth Circuit affirmed. Smith filed suit in the Court of Federal Claims, seeking compensation and equitable relief, alleging violations substantive and procedural due process and of equal protection, and judicial takings of his private property right to practice law and make a living. The Claims Court dismissed, reasoning that absent a money-mandating statute providing for compensation for such government action, it had no jurisdiction and that because the revocation actions became final no later than 1999, suit under the Tucker Act was barred by the six-year limitations period, 28 U.S.C. 2501.. The Federal Circuit affirmed. View "Smith v. United States" on Justia Law

Sharp, a federal supply contractor, submitted a termination compensation claim to the Department of the Army contracting officer, and later brought a Contracts Dispute Act claim before the Armed Services Board of Contract Appeals, claiming that, because the Army failed to exercise the entirety of the last option year under a delivery order, Sharp was entitled to premature discontinuance fees under its General Services Administration schedule contract. The ASBCA dismissed for lack of subject-matter jurisdiction, concluding that the Federal Acquisition Regulation, does not permit ordering agency contracting officers to decide disputes pertaining to schedule contracts. The Federal Circuit affirmed. Under FAR 8.406-6, only the GSA contracting office may resolve disputes that, in whole or in part, involve interpretation of disputed schedule contract provisions. View "Sharp Elec. Corp. v. McHugh" on Justia Law

Walker served in the U.S. Army Air Force, 1943 to 1945, as a four-engine airplane pilot and flight instructor. The VA Regional Office denied his 2007 disability claim for bilateral hearing loss. Walker appealed to the Board of Veterans Appeals, including sworn statements from his son and wife that his hearing loss began in service and continued throughout his life. Walker was examined by a VA audiologist. Walker’s service medical records were not available due to a fire. The audiologist concluded that the hearing loss was “less likely as not caused primarily by military service as a pilot,” that age could not be excluded as the primary etiology, and that Walker was exposed to recreational noise by hunting game without use of hearing protection. The Board concluded that Walker failed under the three-element test to establish service connection for his hearing loss. The Federal Circuit affirmed. View "Walker v. Shinseki" on Justia Law