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

The case revolves around SnapRays, a Utah-based company that designs, markets, and sells electrical outlet covers with integrated guide lights, safety lights, motion sensor lights, and USB charging technology, and Lighting Defense Group (LDG), an Arizona-based company that owns a patent related to a cover for an electrical receptacle. LDG submitted an Amazon Patent Evaluation Express (APEX) Agreement alleging that certain SnapPower products sold on Amazon.com infringed its patent. SnapPower subsequently filed an action for declaratory judgment of noninfringement.The United States District Court for the District of Utah dismissed SnapPower's complaint for lack of personal jurisdiction over LDG. The court concluded that LDG lacked sufficient contacts with Utah for it to exercise specific personal jurisdiction. It found that LDG's allegations of infringement were directed toward Amazon in Washington, where the APEX Agreement was sent, and not at SnapPower in Utah. The court also noted that under Federal Circuit law, principles of fair play and substantial justice support a finding that LDG is not subject to specific personal jurisdiction in Utah.The United States Court of Appeals for the Federal Circuit reversed the lower court's decision. The appellate court concluded that LDG purposefully directed extra-judicial patent enforcement activities at SnapPower in Utah, thereby satisfying the requirements for specific personal jurisdiction. The court found that LDG's submission of the APEX Agreement to Amazon, which identified SnapPower's listings as allegedly infringing, was an intentional action aimed at affecting SnapPower's sales and activities in Utah. The court also rejected LDG's argument that the assertion of specific personal jurisdiction over it in Utah would be unfair and unreasonable. The case was remanded for further proceedings. View "SNAPRAYS v. LIGHTING DEFENSE GROUP " on Justia Law

The case revolves around Intellectual Tech LLC (IT), a wholly owned subsidiary of OnAsset Intelligence, Inc. (OnAsset), and its patent dispute with Zebra Technologies Corporation (Zebra). In 2019, IT asserted U.S. Patent No. 7,233,247 against Zebra, claiming that it was the owner and assignee of the patent. However, Zebra moved to dismiss the complaint, arguing that IT lacked standing. The district court initially denied the motion, but later granted it based on its determination that IT lacked constitutional standing, leading to the dismissal of all claims without prejudice.Previously, OnAsset had granted Main Street Capital Corporation (Main Street), a lender, a security interest in its patents, including the one in question, as part of a loan agreement. When OnAsset defaulted on the loan, Main Street gained certain rights. Subsequently, OnAsset assigned the patent to IT, which also defaulted on its obligations. The district court found that Main Street's ability to license the patent upon default deprived IT of all its exclusionary rights, leading to a lack of constitutional standing.The United States Court of Appeals for the Federal Circuit disagreed with the district court's interpretation. The appellate court found that IT retained at least one exclusionary right, even considering the rights Main Street gained upon default. The court clarified that a patent owner has exclusionary rights as a baseline matter unless it has transferred all exclusionary rights away. The court concluded that IT still suffered an injury in fact from infringement even if IT and Main Street could both license the patent. Therefore, the appellate court reversed the district court's decision and remanded the case for further proceedings. View "Intellectual Tech LLC v. Zebra Technologies Corp." on Justia Law

The case revolves around a dispute between Jalmar Araujo and Framboise Holdings Inc. over the registration of the standard character mark #TODECACHO. Araujo filed a U.S. Trademark Application to register #TODECACHO for hair combs. Framboise opposed the registration, claiming that it would likely cause confusion with its #TODECACHO design mark, which it had been using in connection with various hair products since March 24, 2017. Framboise also had a pending trademark application for the same mark.The United States Patent and Trademark Office Trademark Trial and Appeal Board (the Board) granted Framboise an extension to submit its case in chief. Araujo opposed this extension and the late submission of a declaration by Adrian Extrakt, Director of Framboise. However, the Board granted the extension, finding that the delay was minimal and that Framboise had met the applicable good cause standard. The Board then relied on the Extrakt declaration to support Framboise's claim of prior use of the #TODECACHO design mark.The Board found that Framboise had met its burden to establish prior use by a preponderance of the evidence. It found that the Extrakt declaration alone was sufficient to prove prior use because it was clear, convincing, and uncontradicted. Having found an earlier priority date for Framboise, the Board found a likelihood of confusion between the two marks, sustained the opposition, and refused registration of Araujo’s mark.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Board's decision. The court found that the Board did not abuse its discretion in granting the extension and that the Board's finding that Framboise established prior use of the #TODECACHO design mark was supported by substantial evidence. View "ARAUJO v. FRAMBOISE HOLDINGS INC. " on Justia Law

The case involves Tony Lamonte Greene and Billie Wayne Byrd, who are incarcerated in an Oklahoma state prison. They, along with seven co-plaintiffs, filed actions in the Court of Federal Claims, arguing that their imprisonment is unlawful and seeking monetary compensation from the United States. They claim to be members of the Cherokee Nation and argue that under certain treaties between the Cherokee Nation and the United States, the State of Oklahoma lacked jurisdiction to prosecute and incarcerate them. They each seek $100 per day for unauthorized detention and more than $1,000,000 in compensatory and punitive damages.The Claims Court dismissed the plaintiffs’ actions for lack of jurisdiction. The court held that the plaintiffs failed to show that the treaties on which they relied gave rise to a personal right to monetary relief on their part in the event of a breach of the covenants relating to the exercise of civil and criminal jurisdiction within the Cherokee Nation. The court explained that claims based on treaties with Indian nations can fall within the jurisdiction of the Claims Court because they are treated as “a species of contract.” However, the court concluded that the treaties were not money-mandating.The United States Court of Appeals for the Federal Circuit affirmed the decision of the Claims Court. The court found that the treaty provisions the appellants relied upon are not money-mandating. The court also noted that the agreements addressed the respective rights of sovereignty of the two contracting parties; they did not create contract-based rights in individuals, the breach of which could give rise to monetary remedies for those individual complainants. The court concluded that the appellants’ claim does not fall within the reach of the Tucker Act, and therefore, the Claims Court lacked jurisdiction to address their demand for damages from the United States attributable to their prosecution and incarceration by the State of Oklahoma. View "GREENE v. US " on Justia Law

The Ute Indian Tribe of the Uintah and Ouray Indian Reservation brought a suit against the United States, alleging various claims concerning water rights and water-related infrastructure. The Tribe claimed that the United States breached duties of trust by mismanaging water rights and infrastructure held by the United States and operated for the Tribe, breached contracts with the Tribe, and effected unconstitutional takings of the Tribe’s property. The Claims Court dismissed all the breach of trust claims, held that one breach of contract claim was barred by a 2012 settlement agreement, and found the remaining breach of contract and takings claims time barred.The United States Court of Appeals for the Federal Circuit affirmed in part and vacated and remanded in part the Claims Court's decision. The Court of Appeals held that the Winters doctrine and the 1899 Act did not sufficiently establish trust duties to support Indian Tucker Act jurisdiction with respect to the Tribe’s claims that the United States has a duty to construct new infrastructure and secure new water for the Tribe. However, the Court found that the 1906 Act imposes trust duties on the United States sufficient to support a claim at least with respect to management of existing water infrastructure. The Court also affirmed the dismissal of one breach of contract claim, vacated and remanded another, and affirmed the dismissal of the takings claims. View "UTE INDIAN TRIBE OF THE UINTAH & OURAY INDIAN RESERVATION v. US" on Justia Law

Kevin D. Jones, an attorney, held a term position with the U.S. Department of Agriculture (USDA) before transferring to the Department of Justice’s (DOJ) Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). At the USDA, Jones primarily provided advice and counsel regarding discrimination complaints filed against the agency and litigated ensuing discrimination claims before the Equal Employment Opportunity Commission (EEOC). At the ATF, Jones served as an advisor to the Professional Review Board (PRB) as part of a team of attorneys in the Management Division of the ATF Office of General Counsel (OGC). After three months at the ATF, Jones was asked to resign due to his lack of contract law experience. Jones filed a complaint alleging discrimination and lack of due process in his termination.The Merit Systems Protection Board (MSPB) dismissed Jones's administrative appeal for lack of jurisdiction. The Administrative Judge (AJ) of the MSPB found that Jones was not an "employee" as defined by 5 U.S.C. § 7511(a)(1)(B) because his positions at the USDA and ATF were not the same or similar. The AJ noted several distinctions between the tasks Jones performed at each agency. Jones did not appeal the Initial Decision to the full Board, so the AJ’s Initial Decision became the Final Decision of the Board.The United States Court of Appeals for the Federal Circuit affirmed the Board's decision. The court found that the AJ did not err in her determination that Jones's positions at the USDA and ATF were not similar. The court also found that the AJ's decision was supported by substantial evidence. Therefore, the court affirmed the Board's determination that it lacked jurisdiction to hear Jones's appeal. View "Jones v. Merit Systems Protection Board" on Justia Law

The case involves Benito R. Chavez, a Vietnam War veteran who sought service connection for posttraumatic stress disorder (PTSD). After being diagnosed with chronic, moderately severe PTSD, he was granted a 100 percent disability evaluation by the Department of Veterans Affairs (DVA). However, after a subsequent medical examination, his disability rating was reduced to 50 percent, and later increased to 70 percent, as it was determined that his condition did not result in total occupational impairment. Chavez disagreed with this decision and appealed to the Board of Veterans’ Appeals, which upheld the reduction.Chavez then appealed to the Court of Appeals for Veterans Claims, arguing that the Board's decision should be reversed and his 100 percent rating reinstated. The Veterans Court agreed that the Board may have improperly relied on evidence developed after the rating reduction, but instead of reversing the Board’s decision, it remanded the case back to the Board for further examination.Chavez appealed this decision to the United States Court of Appeals for the Federal Circuit, arguing that the Veterans Court should have reversed the Board’s decision rather than remanding the case. The government contended that the Federal Circuit lacked jurisdiction over Chavez's appeal. The Federal Circuit rejected the government's jurisdictional argument but affirmed the decision of the Veterans Court on the merits. The Federal Circuit held that the Veterans Court was fully entitled to remand the case to the Board for clarification, and therefore, the decision of the Veterans Court was affirmed. View "Chavez v. McDonough" on Justia Law

The case revolves around a minor, A.L., who developed immune thrombocytopenic purpura after receiving the DTaP, Hib, and MMR vaccines. Her parents, Victoria and Kevin Leming, filed a petition for compensation under the National Childhood Vaccine Injury Act (the “Vaccine Act”), alleging that the vaccines caused A.L.'s condition. The Lemings argued that A.L.'s condition met the "surgical intervention" severity requirement of the Vaccine Act, as she was hospitalized for two weeks and underwent a bone marrow aspiration and biopsy.The Court of Federal Claims initially ruled that the Lemings could not establish by a preponderance of the evidence that A.L. satisfied the “surgical intervention” severity requirement. The court held that the bone marrow aspiration and biopsy performed on A.L. was purely diagnostic and did not qualify as a "surgical intervention" under the Vaccine Act. On appeal, the case was reassigned to another special master who requested the Lemings offer more evidence to address the “residual effects” prong of the severity requirement. The Lemings failed to prove that A.L. suffered from the “residual effects” of the vaccine injury for more than six months.The United States Court of Appeals for the Federal Circuit reversed the lower court's decision. The appellate court held that the term “surgical intervention,” as used in the Vaccine Act, requires a surgical act or measure, either diagnostic or therapeutic, taken to prevent harm to a patient or to improve the health of a patient. The court found that the bone marrow aspiration and biopsy performed on A.L. was a surgical intervention as it was a surgical act taken to improve the health of and prevent harm to A.L. The case was remanded for further proceedings consistent with this opinion. View "LEMING v. HHS " on Justia Law

This case involves a dispute between two manufacturers of dining mats for toddlers, Luv n' Care, Ltd. and Nouri E. Hakim (collectively, “LNC”), and Lindsey Laurain and Eazy-PZ, LLC (collectively, “EZPZ”). LNC filed a lawsuit against EZPZ, seeking a declaratory judgment that EZPZ’s U.S. Patent No. 9,462,903 (the “’903 patent”) is invalid, unenforceable, and not infringed. EZPZ counterclaimed, alleging infringement of the ’903 patent, among other claims. After a bench trial, the district court found that LNC failed to prove that the ’903 patent is unenforceable due to inequitable conduct, but that EZPZ was barred from obtaining relief due to its “unclean hands.” The court also granted LNC’s motion for partial summary judgment that the claims of the ’903 patent are invalid as obvious. Both parties appealed.The United States Court of Appeals for the Federal Circuit affirmed the district court’s judgment on the doctrine of unclean hands, meaning that EZPZ was barred from obtaining relief due to its misconduct during the litigation. However, the court vacated the district court’s judgment on inequitable conduct and invalidity, finding that there were genuine disputes of material fact that precluded summary judgment. The court also vacated the district court’s denial of LNC’s motion for attorney fees and costs, and remanded the case for further proceedings. View "Luv n' Care, Ltd. v. Laurain" on Justia Law

The case involves Salix Pharmaceuticals, Ltd., Salix Pharmaceuticals, Inc., Bausch Health Ireland Ltd., and Alfasigma S.P.A. (collectively, “Salix”) and Norwich Pharmaceuticals Inc. (“Norwich”). Salix appealed from a final judgment of the United States District Court for the District of Delaware holding certain claims of their patents invalid as obvious. Norwich cross-appealed from an order that issued after the district court concluded that Norwich infringed certain claims of Salix's patents and had failed to prove those claims were invalid.Salix's patents were related to the treatment of hepatic encephalopathy (“HE”) and irritable bowel syndrome with diarrhea (“IBS-D”) using a specific dosage of the drug rifaximin, and to a specific polymorphic form of rifaximin. The district court found that Norwich's Abbreviated New Drug Application (“ANDA”) for a generic version of rifaximin infringed Salix's patents, but also held certain claims of Salix's patents invalid as obvious.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court's decision. The court found no clear error in the district court's conclusion that a skilled artisan would have had a reasonable expectation of success in administering the claimed dosage regimen for the treatment of IBS-D. The court also affirmed the district court's conclusion that the polymorph patent claims were invalid as obvious. The court further affirmed the district court's order setting the effective approval date of Norwich's ANDA to be no earlier than the date of expiration of the last to expire of the HE patents, and the district court's denial of the motion to modify the final judgment. View "Salix Pharmaceuticals, Ltd. v. Norwich Pharmaceuticals Inc." on Justia Law