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

In this case, the parents of W.J., a young man with a chromosomal abnormality and autism, brought a case under the National Childhood Vaccine Injury Act of 1986 against the Secretary of Health and Human Services, claiming that the Measles, Mumps, and Rubella vaccine administered to their son had caused or significantly aggravated his health issues. They filed their petition more than 15 years after the vaccine was administered, well beyond the Act's three-year statute of limitations. The parents argued that the statute of limitations should be equitably tolled due to their son's mental incapacitation, his minority status, and the government's alleged fraudulent concealment of a connection between the vaccine and autism.The United States Court of Appeals for the Federal Circuit affirmed the decision of the United States Court of Federal Claims, which had denied the parents' petition for review and confirmed a special master’s decision to dismiss the case as untimely. The court concluded that the mental incapacitation of the son did not qualify as an "extraordinary circumstance" warranting equitable tolling because the parents, as his legal guardians, had failed to demonstrate that they were unable to file a claim on his behalf. The court also rejected the arguments for minority tolling and fraudulent concealment, finding no basis for these in the Vaccine Act or its legislative history. The court further held that the special master had not erred in raising the issue of the statute of limitations, nor in dismissing the claim for failure to state a claim upon which relief could be granted. View "W. J. v. Health and Human Services" on Justia Law

Promptu Systems Corp. sued Comcast Corp. alleging that Comcast infringed on its U.S. Patent Nos. 7,047,196 and 7,260,538. The patents cover a method of using speech recognition services in combination with cable television or video delivery. The case was litigated in the United States District Court for the Eastern District of Pennsylvania. The district court adopted claim constructions that were mostly in line with Comcast's proposals. As a result, Promptu and Comcast agreed to dismiss Promptu's patent-infringement claim and state-law claims with prejudice. Promptu also agreed to a final judgment of no infringement by Comcast of the ’196 and ’538 patents, based on the claim constructions adopted by the district court.Promptu appealed the judgment, challenging several of the underlying claim constructions. The United States Court of Appeals for the Federal Circuit found that the district court incorrectly construed certain claim terms and therefore vacated the judgment and remanded the case for further proceedings. The court held that the district court's constructions of the terms "back channel," "multiplicity of received identified speech channels," "speech recognition system coupled to a wireline node," and "centralized processing station" were not accurate. The court provided detailed analysis and reasoning for these conclusions. The court did not rule on the merits of the infringement claims, but instead remanded the case for further proceedings based on the corrected claim constructions. View "PROMPTU SYSTEMS CORPORATION v. COMCAST CORPORATION " on Justia Law

The plaintiff, Great Northern Properties, L.P. ("GNP"), filed a lawsuit against the United States, alleging a Fifth Amendment taking of its coal leases on the Otter Creek property in Montana. GNP claimed that the federal government, through the Montana state regulatory authority, denied the necessary permits for coal mining. The United States Court of Appeals for the Federal Circuit affirmed the decision of the Court of Federal Claims, which dismissed the case for lack of subject matter jurisdiction. The court held that GNP could not establish that Montana's actions were coerced by the federal government or that Montana acted as an agent of the federal government. The court also noted that the federal government did not dictate the outcome in individual permitting cases and that state law governed the permitting process. Therefore, the federal government was not responsible for the permit denial, as Montana was not coerced to enact its own regulatory program following the passage of the Surface Mining Control and Reclamation Act. Furthermore, the court rejected GNP's claim that the existence of federal standards created an agency relationship between the federal government and Montana. View "GREAT NORTHERN PROPERTIES, L.P. v. US " on Justia Law

A veteran, Robert Stinson, appealed to the United States Court of Appeals for the Federal Circuit, challenging the decision made by the U.S. Court of Appeals for Veterans Claims. The lower court affirmed the Board of Veterans’ Appeals’ denial of Mr. Stinson’s request for service connection for his blastic plasmacytoid dendritic cell neoplasm, a rare and aggressive form of cancer. Mr. Stinson argued that the Veterans Court improperly found facts in the first instance when reviewing the Board’s decision and also argued that the Veterans Court incorrectly applied the doctrine of issue exhaustion.The Federal Circuit found that the Veterans Court exceeded its statutory authority by finding facts and weighing evidence in the first instance. Specifically, the Veterans Court determined that Mr. Stinson's in-service symptoms and the location of the lesion giving rise to his BPDCN diagnosis were not relevant to his claim for service connection. The Federal Circuit held that the Veterans Court's conclusion required impermissible factual determinations.The Federal Circuit vacated the decision of the Veterans Court and remanded the case. On remand, the Veterans Court was instructed to remand the case to the Board for further factual development, including whether Mr. Stinson’s in-service symptoms support a manifestation of BPDCN earlier than 2011. This decision serves as a reminder to the Veterans Court to refrain from making factual determinations in the first instance and to focus on reviewing the Board's factual determinations. View "STINSON v. MCDONOUGH " on Justia Law

The United States Court of Appeals for the Federal Circuit reviewed a decision by the Trademark Trial and Appeal Board denying Naterra International, Inc.'s petition for cancellation of Samah Bensalem's BABIES’ MAGIC TEA standard character mark registration. Naterra argued that there was a likelihood of confusion between its BABY MAGIC mark and Bensalem’s BABIES’ MAGIC TEA mark. The Court examined several factors, including the similarity of the marks, the nature of the goods, and the trade channels. The Court found that the Board erred in its assessment of the similarity of the marks and the trade channels and failed to properly evaluate relevant evidence about the nature of the goods. Therefore, the Court vacated the Board's decision and remanded the case for further proceedings. The Court also found the Board did not err in its assessment of the fame of Naterra's mark. View "NATERRA INTERNATIONAL, INC. v. BENSALEM " on Justia Law

In 2020, the law firm Chestek PLLC applied for a trademark for the mark "CHESTEK LEGAL" but provided only a P.O. box as its domicile address. The United States Patent and Trademark Office (USPTO) refused the application because it did not comply with the domicile address requirement. Chestek argued that the rules enforcing this requirement were improperly promulgated under the Administrative Procedure Act (APA). The Trademark Trial and Appeal Board affirmed the examiner's refusal. On appeal to the United States Court of Appeals for the Federal Circuit, Chestek argued that the domicile address requirement was improperly promulgated for two reasons: the USPTO was required to comply with the requirements of notice-and-comment rulemaking under 5 U.S.C. § 553 but failed to do so because the proposed rule did not provide notice of the domicile address requirement adopted in the final rule, and the domicile address requirement is arbitrary and capricious because the final rule failed to offer a satisfactory explanation for the domicile address requirement and failed to consider important aspects of the problem it purports to address, such as privacy. The Federal Circuit found the domicile address requirement to be a procedural rule that is exempt from notice-and-comment rulemaking. Furthermore, the USPTO's decision to require the address provided by all applicants to be a domicile address was not arbitrary or capricious for failure to provide a reasoned justification. The court affirmed the Board's refusal to register Chestek's mark. View "In Re CHESTEK PLLC " on Justia Law

The case revolves around a class-action lawsuit brought by Simon A. Soto, a retired Marine Corps member, against the United States government. The dispute concerned the application of a six-year statute of limitations under the Barring Act (31 U.S.C. § 3702) to claims for unpaid combat-related special compensation (CRSC) under 10 U.S.C. § 1413a. Soto argued that the Barring Act's limitations did not apply to CRSC claims. The United States District Court for the Southern District of Texas agreed with Soto, leading the government to appeal to the United States Court of Appeals for the Federal Circuit.The appellate court reversed the lower court's decision, ruling that the Barring Act's six-year statute of limitations applies to CRSC settlement claims. The court reasoned that the CRSC statute does not provide its own settlement mechanism, so these claims are subject to the Barring Act's settlement procedures, including its six-year statute of limitations. The court also rejected Soto's argument that the statute of limitations should be tolled due to the continuous state of war since 1990, stating that this provision only applies to service members on active duty during times of war. The case was remanded to the district court for further proceedings consistent with the appellate court's opinion. View "SOTO v. US " on Justia Law

This case concerns a patent dispute between RAI Strategic Holdings, Inc. (RAI) and Philip Morris Products S.A. (Philip Morris) about an electrically powered smoking article. The United States Court of Appeals for the Federal Circuit affirmed in part, vacated in part, and remanded the decision of the Patent Trial and Appeal Board (Board).RAI owns a patent for electrically powered smoking articles that heat tobacco or other substances without significant combustion. Philip Morris filed a petition to review the patent, asserting that the claims were invalid due to a lack of written description and obviousness over prior art. The Board agreed with Philip Morris and held certain claims of the patent unpatentable.On appeal, RAI argued that the Board erred by finding that some claims lacked adequate written description support and that other claims were obvious. The Court of Appeals agreed with RAI regarding the written-description issue. It found that the patent specification did provide adequate written description support for the disputed claims, as it disclosed the end points of the claimed range and there were no inconsistent statements regarding the range. Thus, the Court of Appeals vacated the Board's decision on this issue and remanded for further consideration.However, the Court of Appeals affirmed the Board’s decision regarding the obviousness issue. It found substantial evidence to support the Board's finding that a person of ordinary skill in the art would have been motivated to combine prior art references, making the claims obvious. Specifically, the Court found that the Board reasonably concluded that a skilled artisan would have been motivated to replace the heating element in Robinson's smoking article with the heating element taught by Greim. Therefore, the Court affirmed the Board’s finding that these claims were unpatentable as obvious. View "RAI Strategic Holdings, Inc. v. Philip Morris Products S.A." on Justia Law

In this case, the University of South Florida Board of Trustees (USF) sued the United States, claiming that the latter infringed a patent owned by USF regarding genetically modified mice for Alzheimer's Disease research. The USF contended that The Jackson Laboratory, with the government's authorization and consent, had been producing and using mice covered by the patent for the government. The government countered the claim by asserting it had a license to practice the patent under a provision of the Bayh-Dole Act, which addresses patent rights in work funded by the federal government. The United States Court of Appeals for the Federal Circuit determined that the provision does apply and therefore affirmed the judgment of noninfringement. The court confirmed that the April 1997 work, the first actual reduction to practice of the invention, was "in the performance of work under a funding agreement." The court also rejected USF's contention that a funding agreement must be in place at the time of the relevant work, clarifying that the Act can cover work already performed before a funding agreement is executed or becomes effective. View "University of South Florida Board of Trustees v. United States" on Justia Law

In a patent dispute between Weber, Inc. and Provisur Technologies, Inc. before the United States Court of Appeals for the Federal Circuit, Weber appealed two final written decisions from the Patent Trial and Appeal Board. The Board had determined that Weber failed to establish the unpatentability of the claims of Provisur’s patents relating to high-speed mechanical slicers used in food-processing plants. The Board found that Weber’s operating manuals were not prior art printed publications and that the prior art did not disclose two challenged claim terms. The Court of Appeals reversed the Board's determinations that Weber's operating manuals do not qualify as printed publications and that the prior art does not disclose the "disposed over" and "stop gate" limitations. The court then vacated the Board's conclusions that Weber failed to establish unpatentability of the challenged claims, and remanded the case for further proceedings. View "WEBER, INC. v. PROVISUR TECHNOLOGIES, INC. " on Justia Law