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

Nidec's patent discloses a system for controlling the torque of an electromagnetic motor. Following an inter partes review, the Patent Trial and Appeal Board found that claim 21 was anticipated. The Federal Circuit reversed that decision as not supported by substantial evidence. The Board incorrectly held that anticipation can be found even when a prior art reference fails to disclose a claim element so long as a skilled artisan reading the reference would “at once envisage” the claimed arrangement. View "Nidec Motor Corp. v. Zhongshan Broad Ocean Motor, LLC" on Justia Law

Non-Russian investors could not invest directly in Russian sovereign debt but could invest in derivative credit-linked notes (CLNs), sold by banks. When Russia defaulted on its sovereign debt in 1998, CLNs lost nearly all of their value. The Russian Central Bank imposed currency exchange limitations that prevented the ruble from being freely traded. Tiger's hedge funds had purchased CLNs for more than $230 million. After the collapse, Tiger needed cash to pay off investors but was unable to sell its CLNs. Zimmerman believed that she could make money by obtaining devalued Russian debt in anticipation of a recovery of the ruble. Bracebridge, in which Zimmerman was a partner, established RRF, a hedge fund. FFIP, another fund managed by Bracebridge contributed RRF's first assets. Tiger transferred CLNs to RRF in exchange for an RRF ownership interest. Tiger sold its RRF partnership shares to FFIP for a discount, although the value of the shares had increased. RRF filed its 2000 tax return, allocating a loss to FFIP. FFIP’s 2001 losses flowed through to Zimmerman. In 2005, the IRS audited the parties, disallowed the loss RRF claimed for the sale of the Tiger CLNs, and imposed a 40% penalty. RRF and Bracebridge sought readjustment of partnership items under the Tax Equity and Fiscal Responsibility Act, I.R.C. 6221–6233. The Claims Court held that the limitations period for assessing taxes against RRF’s indirect partners had expired as to some, but not all, indirect partners and upheld the disallowance of the losses and imposition of penalties. The Federal Circuit affirmed, holding that the losses claimed on Zimmerman’s 2001 tax return are “attributable to” the loss claimed in RRF’s 2000 tax return, the limitations period for which was suspended by the 2005 Final Partnership Administrative Adjustment. Tiger’s contributions to RRF were not valid partnership contributions. View "Russian Recovery Fund Limited v. United States" on Justia Law

In 2014, the Board of Veterans Appeals denied Parrott’s claims for benefits on account of her veteran husband’s esophageal adenocarcinoma, with liver and peritoneal metastasis, and his ensuing death. The Veterans Court vacated and remanded. Parrott then timely sought attorney fees and expenses under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412. The Veterans Court awarded her $4,050. The Federal Circuit affirmed, rejecting arguments that, in arriving at its award of attorney fees, the Veterans Court misinterpreted EAJA and adopted an incorrect approach for determining the cost of living adjustment to be used in calculating her attorney’s hourly rate and that the court then abused its discretion by not allowing her to resubmit her application using the approach the court had adopted. EAJA states that “attorney fees shall not be awarded in excess of $125 per hour unless the court determines that an increase in the cost of living . . . justifies a higher fee.” The court properly rejected Parrott’s request for a cost of living increase, based on Washington D.C., based on the location of the Veterans Court and applied rates based on the locations of her attorney’s offices in San Francisco, Dallas, and Little Rock. View "Parrott v. Shulkin" on Justia Law

Before October 2012, Army emergency medical technicians and paramedics serving at Fort Stewart, Liberty, Georgia (EMTs) were generally scheduled for a compressed schedule consisting of 24 hours on-duty followed by 48 hours off-duty. After October 2012, the EMTs switched to a schedule consisting of two 48-hour workweeks. Because the EMTs remain at their work stations more than 40 hours in one week, they were entitled to Fair Labor Standards Act overtime pay. For a typical biweekly pay period, the government compensated the EMTs with basic pay under the Federal Employees Pay Act (Title 5); standby duty premium pay under Title 5; and FLSA overtime pay for regularly scheduled overtime. Current and former EMTs filed suit, alleging that the government underpaid them by using an incorrect formula to calculate FLSA overtime. The Federal Circuit affirmed summary judgment in favor of the government. The EMTs receive “the straight time rate of pay times all overtime hours worked” when the government pays them annual premium standby pay in addition to basic pay. The EMTs are not entitled to a windfall, particularly where the very nature of standby work means that the employees are not actively working all hours for which they receive pay. View "Alamo v. United States" on Justia Law

TVI’s patent discloses an inertial tracking system for tracking the motion of an object relative to a moving reference frame. Inertial sensors, such as accelerometers and gyroscopes, measure specific forces associated with changes in a sensor’s position and orientation relative to a known starting positionl they are used in various applications, including aircraft navigation and virtual reality simulations. When mounted on a moving object, inertial sensors can calculate the position, orientation, and velocity of the object in three-dimensional space, based on a specified starting point, without any other external information. The Federal Circuit reversed the Claims Court’s determination that certain claims were directed to patent-ineligible subject matter, 35 U.S.C. 101. The claims are not directed to an abstract idea, but specify a particular configuration of inertial sensors and a particular method of using the raw data from the sensors in order to more accurately calculate the position and orientation of an object on a moving platform. The mathematical equations are a consequence of the arrangement of the sensors and the unconventional choice of reference frame in order to calculate position and orientation. Far from claiming the equations themselves, the claims seek to protect only the application of physics to the unconventional configuration of sensors as disclosed. View "Thalex Visionix Inc.. v. United States" on Justia Law

Comcast sued Sprint for infringement of the Low Patents, which are in the same patent family and are generally directed to methods of using Domain Name System (DNS) technology, such as the Internet, to initiate and route a phone call through a switched telecommunication system. A jury found that Sprint’s handling of certain phone calls infringed various claims and awarded Comcast a $7.5 million damages award. The district court denied Sprint’s motion for judgment as a matter of law or for a new trial, and added prejudgment interest to the damages award. The Federal Circuit affirmed, upholding findings that “[a] system with elements of both switches and a ‘datagram-based system’ is not necessarily outside the scope of a ‘switched telecommunication system.’”; “A ‘communication system’ is still a broader concept than a ‘switched telecommunication system’ even where the ‘switched telecommunication system’ has elements of a ‘datagram-based system,’ because a ‘switched telecommunication system’ at a minimum must have switches and function on a bearer network”; and that “parsing” was an automated process because it necessarily required a computer. View "Comcast IP Holdings I LLC v. Sprint Communications Co." on Justia Law

Meiresonne is the sole inventor of the 096 patent, titled “Supplier Identification and Locator System and Method,” disclosing a “system whereby a user can identify a supplier of goods or services over the Internet.” It teaches a directory website that contains a plurality of links to supplier websites, “a supplier descriptive portion” located near a corresponding supplier link, “a descriptive title portion” describing the class of goods or services listed on the website, and “a rollover window that displays information” about at least one of the suppliers corresponding to a link. The Federal Circuit affirmed the determination of the U.S. Patent and Trademark Office’s Patent Trial and Appeal Board, on inter partes review, that four claims are unpatentable under 35 U.S.C. 103. The Board’s fact finding that prior art references do not teach away from combining text descriptions with additional information in a rollover viewing area is supported by substantial evidence. View "Meiresonne v. Google, Inc." on Justia Law

IV sued Capital One, alleging infringement of three patents. Capital One asserted antitrust counterclaims against IV under the Sherman Act and moved for summary judgment on IV’s infringement claims, arguing that the 081 and 002 patents were invalid under 35 U.S.C. 101. In a related proceeding, the district court entered a partial summary judgment order of ineligibility under section 101 for the 084 patent. The district court invalidated the 081 and 002 patents under section 101 and barred IV from proceeding on its infringement claims as to the 084 patent under a collateral estoppel theory. The Federal Circuit, having affirmed in the related proceeding, also affirmed in favor of Capital One. The partial summary judgment order with respect to the 084 patent met the finality prong for the purposes of collateral estoppel. The claims of the 081 patent are, at their core, directed to the abstract idea of collecting, displaying, and manipulating data, and are patent-ineligible; taken individually or in combination, the recited limitations neither improve the functions of the computer itself, nor provide specific programming, tailored software, or meaningful guidance for implementing the abstract concept. The court noted that the 002 patent had been found ineligible in a related proceeding. View "Intellectual Ventures I LLC v. Capital One Financial Corp." on Justia Law

IV sued insurance companies, alleging infringement of three patents. The insurers moved to dismiss IV’s 581 patent infringement claims for lack of standing and argued that all three patents were directed to ineligible subject matter under 35 U.S.C 101. After concluding that IV did not own the rights to the 581 patent, the district court dismissed those claims for lack of standing, finding that a particular assignor did not assign any rights in or to the then-pending application to the 581 patent, thus breaking a chain in ownership of the patent. The court also found the three patents ineligible under section 101. The Federal Circuit agreed that IV had not been assigned any rights in the 581 patent and lacked standing. The court also agreed that the 434 patent, reciting “no more than routine steps involving generic computer components and conventional computer data processing activities to accomplish the well-known concept of creating an index and using that index to search for and retrieve data” was patent-ineligible. The 002 patent, reciting the abstract idea of remotely accessing user-specific information, identifies a need, but the claims fail to provide a concrete solution to address that need. View "Intellectual Ventures I LLC v. Erie Indemnity Co." on Justia Law

Prism’s patents describe methods and systems for managing access to protected information provided over certain “untrusted” networks. The technology involves an access server, an authentication server, and a client. The access server forwards client requests for protected information to the authentication server. If the authentication server, using stored identity data, successfully authenticates the client, the client receives authorization to access the information. After the court construed “Internet Protocol network” and similar limitations as “an untrusted network using any protocol of the Internet Protocol Suite including at least one of IP, TCP/IP UDP/IP, HTTP, and HTTP/IP.” and defined an “untrusted” network as “a public network with no controlling organization, with the path to access the network being undefined and the user being anonymous,” a jury found Sprint liable for infringement and awarded Prism $30 million in reasonable-royalty damages under 35 U.S.C. 284. The district court denied Prism’s motion for additional monetary relief for times after the period Prism said was covered by the jury verdict. The Federal Circuit affirmed, upholding the court’s admission of evidence of a settlement between Prism and AT&T in a suit involving similar allegations and other evidentiary rulings. View "Prism Technologies LLC v. Sprint Spectrum L.P." on Justia Law