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

Valeo North America imported T-series aluminum sheets from China and sought a determination from the U.S. Department of Commerce as to whether these products were subject to existing antidumping and countervailing duty orders on common alloy aluminum sheet from China. The dispute centered on whether Valeo’s T-series sheets, which have a manganese-based core but are not registered with the Aluminum Association, fell within the scope of the orders, which cover certain aluminum sheets “as designated by the Aluminum Association.” Valeo argued that only registered alloys were covered and that its heat-treated T-series sheets should be excluded.The United States Department of Commerce initially ruled that Valeo’s T-series sheets were within the scope of the orders, interpreting the language to include unregistered alloys with the relevant chemical composition. Valeo challenged this determination at the United States Court of International Trade, which found the scope language ambiguous and remanded the case for further explanation, particularly regarding the treatment of unregistered alloys and the impact of heat treatment. On remand, Commerce again found the scope language ambiguous, considered additional regulatory factors, and reaffirmed that Valeo’s products were covered. The Trade Court sustained this remand determination, and Valeo appealed.The United States Court of Appeals for the Federal Circuit reviewed the case de novo. It held that the language “as designated by the Aluminum Association” in the orders was ambiguous and did not unambiguously exclude unregistered alloys. The court found that Commerce’s analysis under the regulatory framework was supported by substantial evidence and that Valeo’s arguments regarding heat treatment and the timing of Customs instructions were unpersuasive. The Federal Circuit affirmed the Trade Court’s decision, upholding Commerce’s determination that Valeo’s T-series sheets are within the scope of the antidumping and countervailing duty orders. View "VALEO NORTH AMERICA, INC. v. US " on Justia Law

The dispute centers on a patent for a system that automates the adjustment of selectorized dumbbells using an electric motor. The patent describes a dumbbell with stacks of weight plates on each side, a handle, and a movable selector that, when positioned, couples different numbers of plates to the handle. The innovation lies in using an electric motor, operatively connected to the selector, to move it into the desired position based on user input, thereby automating the weight selection process and addressing safety and convenience issues present in prior manual systems.The United States District Court for the District of Utah reviewed the case after the defendant moved to dismiss the complaint, arguing that the asserted patent claims were ineligible under 35 U.S.C. § 101. The district court applied the Supreme Court’s two-step framework for patent eligibility and determined that all but one claim (claim 19) were directed to an abstract idea and implemented using generic components, thus failing the eligibility test. The court granted the motion to dismiss as to claims 1–18 and 20, but denied it for claim 19, finding that the parties had not sufficiently addressed its eligibility.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s decision de novo. The Federal Circuit held that the relevant claims were not directed to an abstract idea but instead to a specific mechanical improvement in selectorized dumbbells. The court found that the claims recited a sufficiently specific structure and method, including the use of an electric motor to automate weight selection, and thus did not preempt all forms of automated weight adjustment. The Federal Circuit reversed the district court’s dismissal of claims 1–18 and 20 and remanded the case for further proceedings. View "POWERBLOCK HOLDINGS, INC. v. IFIT, INC. " on Justia Law

The dispute centers on allegations by Mondis Technology Ltd. and related entities that LG Electronics Inc. and its U.S. subsidiary infringed claims 14 and 15 of U.S. Patent No. 7,475,180. The patent describes a display unit, such as a computer monitor, that stores identification numbers in memory to control access by external devices. The key issue was whether the patent’s written description supported a claim limitation requiring an “identification number for identifying at least a type of said display unit,” as opposed to identifying a specific unit.After Mondis filed suit in the Eastern District of Texas, the case was transferred to the United States District Court for the District of New Jersey and stayed for patent reexamination. When some claims survived, litigation resumed on claims 14 and 15. A jury found the claims not invalid and infringed, awarding damages to Mondis. The district court denied LG’s motion for judgment as a matter of law (JMOL) on invalidity, relying on the presumption of validity and the jury’s ability to weigh expert testimony. The court vacated the initial damages award and ordered a retrial, after which a reduced damages award was entered. Both parties appealed.The United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL. The appellate court held that no reasonable jury could find the patent’s written description adequately supported the claim limitation requiring identification of a type of display unit. The court found that the patent only disclosed identification of specific units, not types, and that neither expert testimony nor the prosecution history provided substantial evidence to the contrary. The Federal Circuit reversed the district court’s judgment, held claims 14 and 15 invalid for lack of written description, and ordered judgment for LG. All other issues were deemed moot. View "Mondis Technology Ltd. v. LG Electronics Inc." on Justia Law

The case involves Tau-Ken Temir LLP, JSC NMC Tau-Ken Samruk, and the Ministry of Trade and Integration of the Republic of Kazakhstan (collectively, "Tau-Ken") appealing a decision by the U.S. Court of International Trade. The U.S. Department of Commerce had determined that the Republic of Kazakhstan subsidized Tau-Ken’s production of silicon metal, warranting a countervailable subsidy rate of 160%. This determination was based on Commerce rejecting a Tau-Ken submission that was filed 1 hour and 41 minutes past the deadline.The U.S. Court of International Trade sustained Commerce’s decision, finding that Commerce did not abuse its discretion in rejecting the late submission and applying an adverse inference when selecting from facts otherwise available. The Trade Court likened the case to Dongtai Peak Honey Industries Co. v. United States, where Commerce had similarly rejected untimely submissions.The United States Court of Appeals for the Federal Circuit reviewed the case and found that Commerce abused its discretion in rejecting Tau-Ken’s submission. The court noted that the rejection significantly impeded the goal of determining an accurate countervailable subsidy rate and that accepting the late submission would not have burdened Commerce or implicated finality concerns. The court also found that Tau-Ken had made diligent efforts to comply with the deadlines and that the technical issues encountered were legitimate.The Federal Circuit vacated the Trade Court’s judgment and remanded the case with instructions for Commerce to accept the September 16 submission and proceed with the countervailing duty investigation accordingly. The court emphasized the importance of determining subsidy rates as accurately as possible and found that Commerce’s rejection of the submission was a clear error of judgment. View "TAU-KEN TEMIR LLP v. US " on Justia Law

Rodney Wright, a totally disabled veteran, sought additional compensation for his adult daughter, B.W., under 38 U.S.C. § 1115(1)(F) after she elected to receive benefits from the Survivors’ and Dependents’ Educational Assistance (DEA) program. The Department of Veterans Affairs (VA) ceased paying Wright additional compensation for B.W. once she began receiving DEA benefits, citing 38 U.S.C. § 3562(2), which bars increased rates or additional amounts of compensation when a dependent elects DEA benefits.The Board of Veterans’ Appeals denied Wright’s request for additional compensation, and the U.S. Court of Appeals for Veterans Claims affirmed the Board’s decision. The Veterans Court held that section 3562 permanently barred Wright from receiving additional compensation under section 1115 once B.W. elected to receive DEA benefits.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the Veterans Court’s decision. The Federal Circuit held that the nonduplication provision of section 3562 bars a disabled veteran from receiving additional compensation under section 1115(1)(F) once the veteran’s child begins receiving DEA benefits. The court also determined that this bar is permanent and does not lift after the exhaustion of DEA benefits. The court rejected Wright’s argument that the bar should only apply to concurrent receipt of benefits, finding no statutory basis for such an interpretation. The court concluded that section 3562 imposes a permanent bar on a veteran’s receipt of additional compensation under section 1115(1)(F) once the veteran’s child elects to receive DEA benefits. View "WRIGHT v. COLLINS " on Justia Law

FMC Corporation owns U.S. Patent Nos. 9,107,416 and 9,596,857, which relate to insecticidal and miticidal compositions. FMC sued Sharda USA, LLC for patent infringement, alleging that Sharda's product, WINNER, infringed on these patents. The patents claim compositions comprising bifenthrin and a cyano-pyrethroid, with specific weight ratios. FMC sought a preliminary injunction to prevent Sharda from importing, marketing, selling, or distributing WINNER.The United States District Court for the Eastern District of Pennsylvania initially denied FMC's motion for a temporary restraining order and preliminary injunction. However, the court issued a claim construction of the term "composition," limiting it to stable compositions based on disclosures in the provisional application and a related patent. FMC renewed its motion, and the district court granted a temporary restraining order, which converted into a preliminary injunction. The court rejected Sharda's invalidity defenses, including anticipation and obviousness, based on the construed definition of "composition."The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the district court erred in its construction of "composition" by limiting it to stable compositions, as the asserted patents did not include the stability disclosures present in the provisional application and related patent. The Federal Circuit held that "composition" should be given its plain and ordinary meaning. Consequently, the court found that the district court's anticipation and obviousness analyses were flawed due to the erroneous claim construction.The Federal Circuit vacated the preliminary injunction and remanded the case for further proceedings, instructing the district court to reconsider Sharda's invalidity defenses under the correct claim construction. The court emphasized that Sharda only needed to raise a substantial question of invalidity to defeat the preliminary injunction. View "FMC CORPORATION v. SHARDA USA, LLC " on Justia Law

Plaintiffs-Appellants, owners of bonds issued by the Puerto Rico Sales Tax Financing Corporation (COFINA), sued the United States, alleging a taking of their property under the Fifth Amendment due to the enactment of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). They claimed that the restructuring of COFINA's debts under PROMESA resulted in a significant loss of the principal and interest value of their bonds and their security interest.The United States Court of Federal Claims determined it had subject matter jurisdiction over the case but dismissed it for failure to state a claim. The court found that the enactment of PROMESA by Congress did not constitute sufficient federal government action to support a takings claim. The court reasoned that the actions of the Puerto Rico Oversight Board, which was created by PROMESA and acted autonomously, could not be attributed to the United States as coercive or as an agency relationship.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the decision of the Claims Court. The Federal Circuit held that PROMESA did not displace Tucker Act jurisdiction, as there was no clear congressional intent to withdraw the Tucker Act remedy. The court also agreed with the Claims Court that the United States did not exert coercive control over the Oversight Board's actions, which were necessary to establish a taking. The court concluded that the plaintiffs could not establish that the United States was liable for the alleged taking of their property. The court also found no abuse of discretion in the Claims Court's decision to deny the plaintiffs' request to amend their complaint. View "DINH v. US " on Justia Law

Nikko Cerrone, a sixteen-year-old, received the Gardasil HPV vaccine, Flumist influenza vaccine, and Hepatitis A vaccine on October 7, 2015. He later reported decreased stamina and blood in his stools, leading to a diagnosis of ulcerative colitis (UC) in March 2016. He received a second HPV vaccine dose in February 2016 and a third in June 2016, with no documented reaction to the third dose.Cerrone filed a petition for compensation under the National Vaccine Injury Compensation Program, claiming the vaccines caused his UC. The Chief Special Master of the National Vaccine Injury Compensation Program denied his claim, finding that Cerrone failed to prove causation by a preponderance of the evidence. The Court of Federal Claims upheld this decision.The United States Court of Appeals for the Federal Circuit reviewed the case. The court affirmed the lower court's decision, agreeing that Cerrone did not meet the burden of proof required under the Vaccine Act. The court found that the special master correctly applied the legal standards and that the findings were not arbitrary or capricious. The court noted that the special master found the respondent's experts more credible and persuasive than Cerrone's experts. The court also upheld the special master's conclusion that the evidence did not support a proximate temporal relationship between the vaccinations and the onset of UC. The decision of the Court of Federal Claims was affirmed. View "CERRONE v. HHS " on Justia Law

Jilin Forest Industry Jinqiao Flooring Group Co. ("Jilin") is an exporter of multilayered wood flooring in China. In November 2010, the Department of Commerce ("Commerce") initiated an antidumping investigation into the sale of this product from China, treating China as a non-market economy ("NME") country. Commerce applied a presumption that all companies in an NME country are subject to government control and should be assessed a single antidumping duty rate unless they can demonstrate independence. Jilin successfully demonstrated independence and received a separate rate of 3.31 percent.In the fifth administrative review initiated in February 2017, Commerce selected Jilin as a mandatory respondent. Despite Jilin's cooperation, Commerce found that Jilin failed to rebut the presumption of government control and assigned it the PRC-wide antidumping duty rate of 25.62 percent. Jilin challenged this decision at the Court of International Trade ("CIT"), which questioned the lawfulness of Commerce's NME policy and ordered Commerce to calculate an individual rate for Jilin. On remand, Commerce calculated a zero percent rate for Jilin under protest, and the CIT entered that rate in its final judgment.The United States Court of Appeals for the Federal Circuit reviewed the case. The court held that Commerce's practice of applying the NME presumption and assigning a single NME-wide rate to exporters that fail to rebut the presumption is lawful. The court cited binding precedents, including Sigma Corp. v. United States and China Manufacturers Alliance, LLC v. United States, which upheld Commerce's authority to use the NME presumption and assign a single rate to the NME-wide entity. The court reversed the CIT's decision, reinstating the PRC-wide antidumping duty rate of 25.62 percent for Jilin. View "JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US " on Justia Law

Super Lighting sued CH Lighting for infringing three patents related to LED tube lamps. CH Lighting conceded infringement of two patents before trial. The district court excluded CH Lighting's evidence on the validity of these two patents and granted Super Lighting's motion for judgment as a matter of law (JMOL) that the patents were not invalid. A jury found the third patent infringed and not invalid, awarding damages for all three patents. CH Lighting appealed.The United States District Court for the Western District of Texas initially reviewed the case. The court excluded evidence from CH Lighting regarding the validity of the two patents and granted JMOL in favor of Super Lighting. The jury found the third patent infringed and awarded damages. CH Lighting's motions for JMOL on invalidity and for a new trial were denied, and the court doubled the damages award.The United States Court of Appeals for the Federal Circuit reviewed the case. The court found that the district court erred in granting JMOL on the validity of the two patents because it improperly excluded CH Lighting's evidence. The court held that a new trial was required to determine the validity of these patents. The court also found that substantial evidence supported the jury's verdicts of infringement and no invalidity for the third patent. Additionally, the court instructed the district court to reassess the reliability of Super Lighting's damages expert's testimony under Rule 702 of the Federal Rules of Evidence. Consequently, the court affirmed in part, reversed in part, vacated in part, and remanded the case for further proceedings. View "JIAXING SUPER LIGHTING ELECTRIC APPLIANCE, CO. v. CH LIGHTING TECHNOLOGY CO., LTD. " on Justia Law