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

The dispute involves two patents held by Magnolia Medical Technologies concerning devices that improve the accuracy of blood tests by reducing contamination from skin microbes. When a blood sample is drawn, contaminants are most likely present in the initial portion, which can cause false positives and unnecessary treatments. Magnolia’s patents aim to sequester this initial blood volume, improving test reliability. Kurin, Inc. manufactures the Kurin Lock, a device that separates the initial blood draw using a porous plug that functions first as a vent and then as a seal.The United States District Court for the District of Delaware initially addressed claim construction. Regarding Magnolia’s U.S. Patent 9,855,001, the court determined that the term “diverter” was a means-plus-function limitation under 35 U.S.C. § 112(f), restricting infringement to devices with corresponding structures detailed in the patent specification. The parties stipulated that the Kurin Lock did not infringe the ’001 patent based on this construction. For U.S. Patent 10,039,483, the case proceeded to trial on the claims related to “vent” and “seal” limitations. The jury found that Kurin Lock infringed these claims. However, Kurin moved for judgment as a matter of law (JMOL), arguing that the Kurin Lock did not have two separate structures corresponding to the “vent” and “seal” as required.The United States Court of Appeals for the Federal Circuit reviewed the district court's claim constructions and JMOL grant. The court held that the district court did not err in construing “diverter” as a means-plus-function term for the ’001 patent. It also affirmed that, under the plain and ordinary meaning and precedent, the ’483 patent required separate structures for “vent” and “seal,” which the Kurin Lock did not possess. The Federal Circuit affirmed the district court’s judgment in favor of Kurin, finding no infringement. View "MAGNOLIA MEDICAL TECHNOLOGIES, INC. v. KURIN, INC. " on Justia Law

The appellants, including trustees of several trusts and Hall Atlas, LLC, held coal mining rights to the Hall Ranch in Wyoming, containing significant coal reserves. In 1985, the Wyoming Department of Environmental Quality (WDEQ) determined that a portion of the Hall Ranch was located on an alluvial valley floor (AVF), which limited mining under the Surface Mining Control and Reclamation Act (SMCRA). For decades, neither the appellants nor Exxon Coal Resources, the lessee at the time, pursued a coal exchange. In 2010, Hall Atlas applied to the Bureau of Land Management (BLM) for a coal exchange. BLM initially rejected WDEQ’s 1985 determination but changed position in 2014, and Hall Atlas submitted a mine plan. In 2016, BLM determined the Hall Ranch AVF coal had a value of $0. In 2017, BLM reiterated its $0 valuation and rejected the appellants’ proposed exchange tract, instead proposing alternatives based on the same valuation.The United States Court of Federal Claims dismissed the appellants’ takings claim for lack of subject matter jurisdiction, holding that the claim was time-barred because it was filed more than six years after the claim accrued. The appellants argued that their claim did not accrue until BLM’s 2017 letter, but the court found that the relevant accrual date was in 2016, when BLM finalized its $0 valuation.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the decision. The Federal Circuit held that any takings claim accrued no later than 2016, making the 2023 filing untimely under the Tucker Act’s six-year statute of limitations. The court rejected arguments for equitable tolling and the application of the continuing claim or stabilization doctrines, and concluded the dismissal for lack of subject matter jurisdiction was correct. The judgment was affirmed and costs were awarded to the appellee. View "WYOMING TRUST CO. v. US " on Justia Law

A United States Army veteran who served in Vietnam from 1969 to 1972 sought increased disability compensation from the Department of Veterans Affairs (VA) due to post-traumatic stress disorder (PTSD). After his retirement from a construction consulting career, the veteran was granted service-connected disability compensation for PTSD, and his rating was eventually increased to 50 percent. In 2021, the veteran applied for a total disability rating based on individual unemployability (TDIU) under 38 C.F.R. § 4.16(b), asserting that his PTSD rendered him unable to secure or follow substantially gainful employment.The Board of Veterans’ Appeals denied the TDIU claim, finding that the veteran’s education, training, and work history demonstrated adaptability, and that he was physically and mentally capable of performing certain jobs with limited social interaction. The Board listed warehouse worker, assembly line worker, and custodian as illustrative occupations he could perform. The United States Court of Appeals for Veterans Claims (Veterans Court) affirmed the Board’s denial, reasoning that the Board was not required to identify actual jobs in the market and that any error in doing so was harmless, relying on precedent that TDIU determinations do not require analysis of specific job market opportunities.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the Veterans Court’s decision. The Federal Circuit held that the Veterans Court may have committed legal error in its harmless-error analysis, specifically by misreading precedent and by applying a rigid rule inconsistent with the proper harmless-error standard. The court vacated the Veterans Court’s decision and remanded for further proceedings, instructing it to reconsider the challenge regarding the Board’s use of illustrative jobs in its TDIU denial. Each party was ordered to bear its own costs. View "JANICH v. COLLINS " on Justia Law

Jennifer Neal was employed by the Department of Veterans Affairs (VA) as a Field Examiner until her removal in August 2020 for alleged unacceptable performance. She challenged her removal before the Merit Systems Protection Board (the Board), arguing that the VA violated the terms of a master collective bargaining agreement by failing to provide her with a performance improvement plan (PIP) prior to removal, and that the performance standards applied to her were unreasonable. During the pendency of her appeal, a Federal Labor Relations Authority (FLRA) decision confirmed the requirement for the VA to provide a PIP before removing bargaining unit employees, as established in a prior arbitration. The administrative judge (AJ) found that the VA's removal of Neal was not in accordance with law and set aside the removal.The VA petitioned for review of the AJ’s decision to the full Board, arguing that the FLRA decision was factually and legally distinguishable. While the petition was pending, the VA voluntarily reinstated Neal, provided her back pay, and otherwise made her whole, effectively granting her all the relief she sought. The Board dismissed the VA’s petition as moot, recognizing that Neal had obtained complete relief. Neal then moved for attorneys’ fees. The AJ granted her request, finding her to be the prevailing party. However, upon the VA’s further petition, the Board reversed, reasoning that because the case became moot before a final Board decision, Neal was not a prevailing party and thus not entitled to fees.The United States Court of Appeals for the Federal Circuit reviewed the Board’s decision. The court held that Neal was a prevailing party because the AJ’s merits decision conferred enduring judicial relief that materially altered the legal relationship between the parties, and the subsequent mootness resulting from the VA’s voluntary compliance did not negate her prevailing party status. The court reversed the Board’s denial of attorneys’ fees and awarded costs to Neal. View "NEAL v. DVA " on Justia Law

The case concerns a dispute between two companies involved in the production and sale of coiled tubing for the oil and gas industry. One company, having acquired assets and documents from a predecessor, developed a coiled tubing product and obtained several patents (the ’256, ’074, and ’075 patents) covering aspects of this technology. The predecessor’s documents disclosed a product with overlapping technical specifications compared to at least some claims of these patents. During the patent application process, the company submitted a related public reference to the Patent and Trademark Office (Chitwood), but did not disclose the predecessor’s internal documents (the CYMAX Documents) that contained additional details. Internal discussions reflected uncertainty among inventors and counsel about the relevance and necessity of disclosing these documents.After disputes arose in the marketplace over alleged patent infringement, the manufacturer of a competing product initiated litigation in the United States District Court for the Southern District of Texas, seeking a declaration of non-infringement. The patent holder counterclaimed for infringement and, as the case proceeded, the competitor amended its claims to include allegations of inequitable conduct (fraud on the Patent Office by withholding material information) and Walker Process fraud (antitrust liability for enforcing a patent obtained by fraud). The district court granted summary judgment to the competitor on the inequitable conduct claim, finding clear evidence of intent to deceive and materiality, and granted summary judgment to the patent holder on the Walker Process fraud claim, finding insufficient evidence of market power.On appeal, the United States Court of Appeals for the Federal Circuit vacated both summary judgment rulings. The appellate court held that genuine disputes of material fact precluded summary judgment on both inequitable conduct and Walker Process fraud. The court remanded for further proceedings, allowing both claims to proceed, and affirmed the denial of summary judgment for the patent holder on inequitable conduct. View "GLOBAL TUBING LLC v. TENARIS COILED TUBES LLC " on Justia Law

The plaintiff, a company seeking a refund of customs duties (drawback) on imported petroleum derivatives, filed a drawback claim with U.S. Customs on March 10, 2020, identifying forty-eight import entries and seeking over $1.3 million. Customs did not liquidate the claim within one year, but on April 30, 2021, it liquidated the claim at zero, determining the plaintiff was not entitled to any drawback. The company's appeal did not challenge the merits of this determination but argued that, by operation of law, its claim should have been automatically (“deemed”) liquidated at the amount it initially asserted, because Customs did not act within one year. The critical factual issue was that, while all underlying import entries had been liquidated by March 10, 2021, not all had become final, as finality requires an additional 180-day period after liquidation.The United States Court of International Trade reviewed the case, focusing on the statutory provisions governing when drawback claims are deemed liquidated under 19 U.S.C. § 1504. The court concluded that because the relevant import entries had not yet become final within one year of the drawback claim’s filing, the “deemed liquidation” provision of § 1504(a)(2)(A) did not apply. Instead, the alternative procedures of § 1504(a)(2)(B) governed, which require additional steps by the claimant that were not taken. The court denied the plaintiff's motion for summary judgment and granted summary judgment for the government.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the lower court’s decision. The appellate court held that when the conditions of § 1504(a)(2)(B) are present—specifically, when underlying import entries are not yet final—automatic deemed liquidation under § 1504(a)(2)(A) does not apply. Customs’ action in liquidating the claim at zero was therefore lawful, and the lower court’s judgment was affirmed. View "PERFORMANCE ADDITIVES, LLC v. US " on Justia Law

The plaintiffs in this case, owners of a patent involving genetically engineered host cells containing recombinant DNA sequences, accused the defendants of infringing multiple claims of their patent. The technology at issue centers on human-made host cells that include a recombinant nucleic acid molecule encoding a specific adeno-associated virus (AAV) capsid protein, along with a heterologous non-AAV sequence. These recombinant molecules are created by artificially combining genetic material from different species, a process that does not occur in nature. The patented host cells are used in developing gene therapy products, including a product for treating Duchenne muscular dystrophy.The United States District Court for the District of Delaware reviewed cross-motions for summary judgment on the issue of patent eligibility under 35 U.S.C. § 101. The district court concluded that the asserted claims were ineligible for patent protection, reasoning that they were directed to a natural phenomenon. The court analogized the claims to those at issue in Supreme Court cases such as Funk Brothers Seed Co. v. Kalo Inoculant Co. and Association for Molecular Pathology v. Myriad Genetics, Inc., finding that merely combining natural sequences did not make the claimed invention patentable. The district court held that the claims lacked an inventive concept and granted summary judgment in favor of the defendants.The United States Court of Appeals for the Federal Circuit reviewed the decision de novo. The appellate court held that the patented host cells are not naturally occurring and possess markedly different characteristics from any product of nature, consistent with the Supreme Court’s guidance in Diamond v. Chakrabarty and Myriad Genetics. The Federal Circuit concluded that the claims are not directed to a natural phenomenon and are therefore patent-eligible under § 101. The court reversed the district court’s judgment and remanded the case for further proceedings. View "REGENXBIO INC. v. SAREPTA THERAPEUTICS, INC. " on Justia Law

This case concerns a patent dispute involving input devices for computers. The plaintiff, Genuine Enabling Technology LLC (GET), claimed that Sony’s PlayStation 3 and 4 controllers and consoles infringed several claims of U.S. Patent No. 6,219,730. The patent addresses the problem of limited computer resources by combining data streams from multiple input devices, such as keyboards and sensors, into a single stream. The contested claims include a means-plus-function limitation called “encoding means for synchronizing,” which requires synchronizing two input streams and encoding them into a combined data stream.The U.S. District Court for the District of Delaware handled the case initially. It interpreted the “encoding means” as a means-plus-function limitation and identified logic block 34 in Figure 4A of the patent as the corresponding structure. During litigation, GET’s expert, Dr. Fernald, failed to address most of the elements in logic block 34 when analyzing infringement, focusing primarily on the bit-rate clock signal. The district court excluded Dr. Fernald’s testimony on structural equivalence and ultimately granted Sony summary judgment of noninfringement, finding GET had not raised a genuine issue of material fact regarding infringement.The United States Court of Appeals for the Federal Circuit reviewed the district court’s grant of summary judgment de novo. The Federal Circuit affirmed the lower court’s decision, holding that GET’s infringement analysis was deficient because it did not adequately account for the full structure of logic block 34 required by the patent specification. The court emphasized that GET failed to explain why it was permissible to omit certain elements from its equivalence analysis. Thus, GET lacked sufficient evidence for a reasonable jury to find infringement. The district court’s exclusion of expert testimony and summary judgment were affirmed. View "GENUINE ENABLING TECHNOLOGY LLC v. SONY GROUP CORPORATION " on Justia Law

The dispute centers on a patented pre-lit artificial tree owned by Willis Electric Co., Ltd., which features separable, modular trunk portions that mechanically and electrically connect to one another, enabling attached lights to illuminate automatically regardless of trunk orientation. The prior art required separate mechanical and electrical connections, but Willis’ patent integrates both functions in a single step. Willis accused Polygroup of infringing claim 15 of its patent, specifically targeting Polygroup trees with the “Quick Set” feature that establishes simultaneous mechanical and electrical connections.After Willis initiated the lawsuit in the United States District Court for the District of Minnesota, Polygroup filed multiple inter partes review petitions at the Patent Trial and Appeal Board (PTAB) challenging various claims of Willis’ patent. The PTAB upheld claim 15, and the United States Court of Appeals for the Federal Circuit affirmed that finding. The district court proceedings continued with only claim 15 at issue. Polygroup filed a Daubert motion to exclude Willis’ damages expert, which was denied. At trial, the jury found claim 15 infringed and not invalid, awarding Willis over $42 million in damages. Polygroup then moved for judgment as a matter of law (JMOL) on obviousness and a new trial on damages, but the district court denied both motions.The United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL and the motion for a new trial. The court held that substantial evidence supported the jury’s finding that a skilled artisan would not have been motivated to combine prior art with coaxial barrel connectors as claimed in claim 15, thus affirming nonobviousness. The court also held that the district court did not abuse its discretion in admitting the damages expert’s testimony, finding the methodology sufficiently reliable under Rule 702. As a result, the Federal Circuit affirmed the district court’s judgment in all respects. View "WILLIS ELECTRIC CO., LTD. v. POLYGROUP LTD." on Justia Law

The dispute centers on whether imported plastic shelf dividers containing magnets are subject to U.S. antidumping and countervailing duty orders covering raw flexible magnets from China. Fasteners for Retail, Inc. imports shelf dividers composed of flexible magnets bonded to rigid plastic, which makes the magnets inflexible. The United States Department of Commerce had previously issued duty orders with scope language covering certain flexible magnets, regardless of shape, color, or packaging. Fasteners for Retail requested a scope ruling from Commerce to clarify whether their shelf dividers fell within the scope of these orders.Commerce issued a final scope ruling, finding that although the plain language of the duty orders might appear to include Siffron’s shelf dividers, prior scope rulings and interpretative sources (known as (k)(1) sources) provided further guidance. Based on these sources, Commerce determined that magnets rendered inflexible by attachment to other materials, such as plastic, are not included within the term “flexible magnets” under the duty orders. The United States Court of International Trade reviewed Commerce’s ruling and upheld it, finding Commerce’s determination reasonable and supported by substantial evidence.The United States Court of Appeals for the Federal Circuit reviewed the case de novo, applying the same standard as the Trade Court. The court held that Commerce has discretion under the current regulations to consult (k)(1) sources in interpreting scope language regardless of apparent ambiguity. The court concluded that Commerce’s determination that Siffron’s shelf dividers are not “flexible magnets” under the duty orders was supported by substantial evidence and in accordance with law. Therefore, the Federal Circuit affirmed the judgment of the Court of International Trade, sustaining Commerce’s scope ruling that the shelf dividers are not subject to the duty orders. View "MAGNUM MAGNETICS CORP. v. US " on Justia Law