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

Matthews manufactures cremation equipment, caskets, and bronze memorials for sale to funeral homes. Its Bio Cremation™ product, uses an alkaline hydrolysis process, as an environmentally friendly alternative to incineration, for cremation. Resomation granted Matthews an exclusive license to sell its alkaline hydrolysis equipment in the U.S. In 2007, Biosafe acquired one system and five method patents related to the application of alkaline hydrolysis to the disposal of various types of waste, such as medical waste, infectious agents, and hazardous materials. In 2011, Matthews sought a declaratory judgment of non-infringement, invalidity, and unenforceability of the patents and asserted state-law claims of trade libel, defamation, and tortious interference with contractual relations. Matthews alleged that Biosafe had wrongly accused Matthews of patent infringement, and made false accusations about Matthews to customers, potential customers, and employees. None of the Matthews units had yet been installed. The district court dismissed, finding that Matthews had not made “meaningful preparation” to conduct potentially infringing activity. Given that it had no information regarding the operating parameters of Matthews’ equipment, the court declined to provide “an advisory opinion.” The Federal Circuit affirmed. Matthews’ claims lacked sufficient immediacy and reality to support the exercise of declaratory judgment jurisdiction. View "Matthews Int'l Corp. v. Biosafe Eng'g, LLC" on Justia Law

The 772 application is directed to methods and compositions for recombining DNA in a eukaryotic cell (a cell with a nucleus), such as a human cell. The Board of Patent Appeals and Interferences affirmed rejection of independent claim 29 of the 772 application, as obvious over the combination of a patent and an article. Claim 29 covers a method of recombining DNA in a eukaryotic cell using modified versions of wild-type Int. The Federal Circuit affirmed. The disclosures provide substantial evidence that a person of ordinary skill in the art would have had a reasonable expectation of success for using the modified integrases disclosed in the article in place of wild-type Int in the method taught in the patent. View "In re Droge" on Justia Law

Outside the Box sought a declaratory judgment against Travel Caddy and its distributor. The district court held that Travel Caddy’s patent and its continuation patent are unenforceable in their entirety, based on inequitable conduct in the U.S. Patent and Trademark Office, consisting of failure to disclose that the parent patent was in litigation. The district court otherwise sustained the validity of some claims, but held the other claims of the patents invalid on ground of obviousness. The court held, on summary judgment, that the version of the Outside the Box tool carry case called the Electricians Carryalls infringes various patent claims, but that a modified version called Electricians Bag II and the tool carry case called Heavy-Duty ProTool Bag do not infringe. The court dismissed unfair-competition claims against Travel Caddy. The Federal Circuit reversed the judgment of unenforceability based on inequitable conduct, vacated the rulings of invalidity, affirmed the rulings of noninfringement, and remanded. View "Outside the Box Innovations, LLC v. Travel Caddy, Inc." on Justia Law

In 1942, the U.S. Bureau of Reclamation dammed the upper San Joaquin River near Friant, California. Friant Dam still operates, generates electricity and collects water for agriculture, but causes portions of the river to dry up, leading to extermination of Chinook salmon and other ecological consequences. In 1988 environmental groups sued the federal government, claiming violations of state and federal environmental protection laws. In 2006, the parties reached a settlement that obliged the government to release water to restore and maintain fish populations downstream, while continuing to support surrounding landowners, who depend on the water. Congress subsequently passed the San Joaquin River Restoration Settlement Act, 123 Stat. 1349, directing the Secretary of the Interior to implement the Settlement. In 2009 the Bureau of Reclamation initiated the first release of water. In August 2010, downstream owners sued the government for takings, alleging that the releases unlawfully impaired property rights in the water and inundated their land. Two of the environmental groups involved in the first case moved to intervene as of right. The Court of Federal Claims denied their motion, finding that the groups’ interests were sufficiently aligned with the government’s as to create no foundation for intervention. The Federal Circuit affirmed. View "Wolfsen Land & Cattle Co. v. United States" on Justia Law

In 2007 the Postal Service awarded Tip Top a contract under which the Postal Service would assign individual projects by issuing work orders. In 2009, the Postal Service issued a work order to replace the air conditioning system at the Main Post Office in Christiansted, Virgin Islands, for the price of $229,736.92. As a result of that work Tip Top submitted a claim and request for an equitable adjustment under the Contract Disputes Act, 41 U.S.C. 7101-7109, in the amount of $34,553.77, consisting of a subcontractor’s price for a change, plus 10% profit, 4% insurance, and 4% gross receipts tax, plus $9,655 for “Preparation Costs & Extended Overhead” and $2,745 for “Legal Fees.” The Postal Service Board of Contract Appeals ruled that Tip Top was entitled to recover $2,565. The Board ruled that Tip Top was not entitled to recover the balance of the amount claimed because it had failed to demonstrate that the costs at issue were incurred as a result of the change order. The Federal Circuit reversed and remanded, with directions to grant the appeal in its entirety. The ruling was based upon an error of law and not supported by substantial evidence. View "Tip Top Constr., Inc.v. Donahoe" on Justia Law

Medtronic sought a declaratory judgment of non-infringement and invalidity of reissue patents covering a cardiac resynchronization therapy device (previously called a biventricular pacer). The district court entered judgment of noniinfringement in favor of Medtronic and judgment of validity and enforceability in favor of the patent holder. The Federal Circuit vacated and remanded, holding that the district court relied on a legally incorrect allocation of the burden of proof to find non-infringement in the limited circumstances of the case and incorrectly construed the claim terms in question. View "Medtronic, Inc. v. Boston Scientific Corp." on Justia Law

Landowners along a trail in Missouri and Kansas sought to join an existing “takings” suit against the United States, concerning the Rails-to-Trails program, filed under the Tucker Act. The initial plaintiff characterized her suit as a class action on behalf of herself and similarly situated persons; the owners qualified as such persons. The class action had been filed before the running of the six-year statute of limitations for the Tucker Act; however, the plaintiffs who sought to join as named parties did not do so until after the limitations period had run. The Court of Federal Claims refused to permit the original plaintiff to amend her complaint for joinder of additional plaintiffs; their suits were dismissed as time barred. The Federal Circuit reversed; the merits are before the Court of Federal Claims. In the meantime, the owners filed “protective suits” under 28 U.S.C. 1346, the “Little Tucker Act” which authorizes suits against the government in federal district courts, if damages sought do not exceed $10,000. The district courts declined to stay those suits pending the appeal and dismissed them as time barred. The Federal Circuit vacated and instructed the district courts to dismiss those suits without prejudice. View "Evans v. United States" on Justia Law

The holder of the 946 Patent, “System and Apparatus for Interactive Multimedia Entertainment,” issued in 1995, alleged infringement. The district court found that, during prosecution of the 946 patent, the named inventor and his attorney withheld from the United States Patent and Trademark Office three material references and information about PTO rejections in two related prosecutions, thereby committing inequitable conduct and rendering the 946 Patent unenforceable. The Federal Circuit reversed, stating that there was no evidence of a deliberate decision to withhold the references. View "1ST Media, LLC v. Electronic Arts, Inc." on Justia Law

As a partner of E&Y, Hartman received restricted shares in Cap Gemini as part of a 2000 sale. The agreement provided for an initial sale of 25 percent of the shares to satisfy each partner’s tax liability as a result of the transaction. In 2001 Hartman received a Form 1099-B reflecting that he was deemed to have received $8,262,183, valuing his unsold Cap shares at $148 per share. Hartman’s return for 2000, reported the entire amount as capital gains income. After closing, the value of Cap shares dropped to $56 per share. Hartman voluntarily terminated his employment, forfeiting 10,560 shares of stock. He received a credit for taxes paid on those shares under I.R.C. 1341. In 2003, Hartman filed an amended return for 2000, claiming that he had received only the 25 percent of Cap shares that had been monetized in 2000, with the remainder received in 2001 and 2002. He sought a refund of $1,298,134. The IRS failed to act on the claim. The Claims Court found that Hartman had constructively received all 55,000 shares in 2000 and was not entitled to a tax refund. The Federal Circuit affirmed. View "Hartman v. United States" on Justia Law

The Department of Commerce issued an antidumping duty order on certain stainless steel plate in coils (SSPC). The order states that the products subject to the order are those which are “4.75 mm or more in thickness.” ASB, a Belgian producer of SSPC, requested a scope ruling to determine whether its products, which have nominal thicknesses of 4.75 mm or more but are imported into the U.S. with actual thicknesses less than 4.75 mm, are included within the scope of the order. Commerce determined that the scope of its antidumping order encompasses SSPC having a nominal thickness of 4.75 mm but an actual thickness of less than 4.75 mm. The Court of International Trade affirmed. The Federal Circuit reversed, finding that the ruling was contrary to the plain language of the order. View "Arcelormittal Stainless Belgium, N.V. v. United States" on Justia Law