Justia Patents Opinion Summaries

The dispute centers on three patents owned by the appellant, which describe a method for displaying information to facilitate the return of lost or stolen computers. The patented method involves powering on a computer and automatically displaying a screen with return information, either before or alongside the lock screen, and includes the ability to remotely initiate or change the displayed information without assistance from a user with the computer. The appellant alleged that certain devices sold by LG Electronics, featuring Google or Microsoft’s “Find My Device” software, infringed these patents.Following the appellant’s lawsuit in the United States District Court for the Western District of Texas, Google and Microsoft initiated six inter partes review (IPR) proceedings before the United States Patent and Trademark Office’s Patent Trial and Appeal Board (PTAB), contesting the validity of the patents based on prior art. The PTAB instituted review despite the appellant’s arguments referencing a parallel district court action and concerns about duplicative proceedings. LG, named as a real party in interest, filed a “Sotera stipulation,” agreeing not to pursue in district court any grounds raised in the IPRs, which the PTAB considered in its decision to institute review.The United States Court of Appeals for the Federal Circuit reviewed the PTAB’s final written decisions, which found all challenged claims unpatentable. The Federal Circuit held that it lacked jurisdiction to review challenges tied to the PTAB’s institution decision, specifically regarding the impact of LG’s violation of the Sotera stipulation. On the merits, the court affirmed the PTAB’s construction of the “without assistance” claim limitation, finding no error and concluding that the prior art disclosed the disputed method. The court also determined that the PTAB’s analysis of secondary considerations of non-obviousness was supported by substantial evidence. The court dismissed the appeal in part and affirmed in part, awarding costs against the appellant. View "HAFEMAN v. GOOGLE LLC " on Justia Law

Amarin Pharma, Inc. developed and marketed Vascepa, a drug containing icosapent ethyl. Initially, the Food and Drug Administration (FDA) approved Vascepa for treating severe hypertriglyceridemia (the SH indication). Later, the FDA approved a new use: reducing cardiovascular risk in certain patients (the CV indication), for which Amarin held two method-of-use patents. Hikma Pharmaceuticals USA Inc., a generic manufacturer, sought to market a generic icosapent ethyl. After Amarin’s SH-indication patents were invalidated by a district court, Hikma pursued FDA approval for a “skinny label” generic, carving out the patented CV indication. The FDA approved Hikma’s application with the label limited to the SH indication.Amarin sued Hikma in the United States District Court for the District of Delaware, alleging that Hikma actively induced infringement of Amarin’s CV-indication patents. Amarin argued that various statements in Hikma’s skinny label, patient information leaflet, website, and press releases encouraged infringement. The District Court granted Hikma’s motion to dismiss, finding that the statements did not constitute active encouragement of infringement. The United States Court of Appeals for the Federal Circuit reversed, holding it plausible that a physician could read Hikma’s statements as instructions or encouragement to prescribe the drug for the patented use.The Supreme Court of the United States reviewed the case and held that Amarin failed to state a claim for active inducement under 35 U.S.C. §271(b). The Court clarified that liability requires affirmative “active steps” to encourage infringement, not merely statements that could be read as encouragement. The Court found Hikma’s statements either reflected legal compliance or ordinary industry practice, or were too vague or passive to plausibly constitute active inducement. The Supreme Court reversed the Federal Circuit’s judgment and remanded for further proceedings. View "Hikma Pharmaceuticals USA Inc. v. Amarin Pharma, Inc." on Justia Law

A dispute arose between two companies over patents related to wireless communications for building automation systems. The plaintiff alleged that the defendant’s smart thermostat products infringed four patents, which addressed improvements in wireless network architecture, power and bandwidth usage, and data redundancy within building control systems. At trial, a jury found that the defendant had infringed at least one of the asserted patents (without specifying which), determined that the claims of one patent were not limited to well-understood or routine technology, found another patent’s claims invalid, and awarded the plaintiff lump sum damages.In the United States District Court for the Eastern District of Texas, the defendant moved to dismiss based on patent ineligibility under 35 U.S.C. § 101, but the court denied these motions for the patents at issue, except for one where factual disputes precluded summary judgment. The court also denied the defendant’s post-trial motions, including challenges to the verdict form, jury instructions related to patent eligibility, and motions to exclude expert testimony. The plaintiff, in turn, appealed the district court’s limitation on prejudgment interest.The United States Court of Appeals for the Federal Circuit reviewed the case and determined that the district court’s verdict form, which combined all asserted patents into a single infringement question, violated the defendant’s right to a unanimous verdict. The appellate court vacated both the infringement and damages judgments and remanded for a new trial on those issues. The court also vacated and remanded the § 101 eligibility determination for one patent, requiring further proceedings under the Alice framework. However, the court affirmed the district court’s findings that the asserted claims of two other patents were not directed to abstract ideas and that substantial evidence supported the jury’s verdict of infringement on one patent. Remaining evidentiary and interest issues were dismissed as moot. View "OLLNOVA TECHNOLOGIES LTD. v. ECOBEE TECHNOLOGIES ULC " on Justia Law

AGI SureTrack LLC brought suit against Farmers Edge Inc. and its U.S. subsidiary, alleging infringement of several patents relating to automated systems and methods for capturing, processing, and sharing farming data. The core patented technology involved using a relay device with generic computer components to collect real-time data from various farming equipment, process this information, and share it via an online exchange. The patent claims described a system using a microprocessor, bus connector, GPS receiver, and memory storage, together with software that records and interprets data from farming implements.The United States District Court for the District of Nebraska granted summary judgment in favor of Farmers Edge. The court found that the asserted patent claims were directed to patent-ineligible subject matter under 35 U.S.C. § 101. Specifically, the court concluded that the claims merely used generic computer components to collect and process data and did not constitute an inventive concept. The district court also ruled that the case was not exceptional and denied Farmers Edge’s request for attorney’s fees under 35 U.S.C. § 285.On appeal, the United States Court of Appeals for the Federal Circuit reviewed both AGI’s challenge to the finding of patent ineligibility and Farmers Edge’s cross-appeal regarding exceptionality. The Federal Circuit affirmed the district court’s determination that the asserted patents were not patent-eligible, holding that the claims were directed to an abstract idea and lacked any inventive concept beyond conventional technology. However, the appellate court vacated the district court’s summary determination that the case was not exceptional, finding the lower court failed to provide adequate reasoning or allow both parties to present argument on the issue. The case was remanded for further proceedings on exceptionality and attorney’s fees. View "AGI SURETRACK LLC v. FARMERS EDGE INC. " on Justia Law

Two companies, both joint owners of several patents related to warm-mix asphalt paving, entered into a licensing agreement in 2008 granting an exclusive, worldwide, royalty-bearing license to another company (and, after a reorganization, its successor). The agreement allowed the licensee to manufacture, use, sell, and sublicense the patented products, but required that sublicensing terms be subject to the patent owners’ prior review and approval (not to be unreasonably withheld). The patent owners retained certain rights, including the right to sue for infringement (with shared or independent control depending on the circumstances), receive royalties, and veto sublicenses. The patent owners also kept limited rights to practice the invention for research and to use products purchased from the licensee.In 2024, the patent owners sued two defendants, alleging infringement of the six patents. The defendants moved to dismiss for lack of Article III standing. The United States District Court for the District of Delaware granted the motion, finding that the patent owners had transferred away all exclusionary rights through the license, and that their retained right to sue was not sufficient for constitutional standing. The district court relied on previous decisions holding that a bare right to sue, separated from other substantial patent rights, did not confer standing.On appeal, the United States Court of Appeals for the Federal Circuit reversed. The Federal Circuit held that the patent owners retained an exclusionary right sufficient for Article III standing, namely the right to sue for infringement that was not rendered illusory by the licensee’s rights. The court concluded that the combination of the right to sue, the right to veto sublicenses, and the continuing royalty interest demonstrated a concrete, non-illusory exclusionary interest. The case was remanded for further proceedings. View "A.L.M. HOLDING COMPANY v. ZYDEX INDUSTRIES PRIVATE LTD. " on Justia Law

The case concerns a patent dispute involving a company that owns a patent for a unified electronic banking system. After most of the patent’s claims were found unpatentable in an inter partes review (IPR) before the Patent and Trademark Office, only four claims remained. The company then sued a bank in the United States District Court for the Southern District of Florida, alleging infringement of these remaining claims. The allegations were supported by claim charts and references to the bank’s online services.The district court first struck the original complaint as a “shotgun pleading” and allowed an amended complaint. The amended complaint was also challenged by the defendant, who argued that the remaining claims were invalid for obviousness and, alternatively, for claiming ineligible subject matter, and that the infringement allegations were inadequate. The district court dismissed the case with prejudice, finding the asserted claims invalid for obviousness as they did not add anything patentably distinct from those already invalidated in the IPR, and also held that infringement was not adequately pleaded. The court denied leave to further amend the complaint and subsequently awarded attorneys’ fees to the defendant under 35 U.S.C. § 285, finding the case “exceptional,” and imposed sanctions on plaintiff’s counsel under 28 U.S.C. § 1927 for alleged bad faith litigation.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the dismissal of the complaint, upholding the finding that the patent claims at issue were invalid for obviousness. However, the appellate court reversed the awards of attorneys’ fees and sanctions, holding that the record did not support a finding that the case was exceptional or that counsel acted in bad faith, as required by the respective statutes. Each party was ordered to bear its own costs. View "MCOM IP, LLC v. CITY NATIONAL BANK OF FLORIDA " on Justia Law

Actelion Pharmaceuticals Ltd, holder of patents for pharmaceutical compositions involving epoprostenol, alleged that Mylan Pharmaceuticals Inc.’s proposed generic drug infringed its patents by manufacturing a bulk solution with a pH of 13 or higher, as claimed in the patents. The dispute centered on whether Mylan’s bulk solution met this pH threshold, either literally or under the doctrine of equivalents. Actelion argued that pH should be measured at the solution’s actual (refrigerated) temperature, while Mylan maintained that its product’s pH, when measured at industry standard temperature, did not meet the claimed threshold.The United States District Court for the Northern District of West Virginia held a bench trial after remand from the United States Court of Appeals for the Federal Circuit, which had previously vacated a judgment based on incorrect claim construction. On remand, the district court construed “a pH of 13 or higher” to mean a pH measurement of 12.98 or higher at standard temperature (25±2°C), relying on both intrinsic and extrinsic evidence. The court found no literal infringement, as Mylan’s bulk solution did not meet this threshold at standard temperature. It also ruled that Actelion was barred from asserting infringement by an equivalent due to prosecution history estoppel and the disclosure-dedication rule, and that Actelion had not proven equivalence.On appeal, the United States Court of Appeals for the Federal Circuit reviewed claim construction de novo and factual findings for clear error. The court affirmed the district court’s claim construction, finding that “a pH of 13 or higher” refers to standard-temperature measurement, supported by industry standards and patent evidence. It also upheld the district court’s application of prosecution history estoppel and the disclosure-dedication rule, barring Actelion’s equivalents argument. The judgment for Mylan was affirmed. View "ACTELION PHARMACEUTICALS LTD v. MYLAN PHARMACEUTICALS INC. " on Justia Law

Bissell, Inc. and Bissell Homecare, Inc. accused Tineco Intelligent Technology Co., Ltd. and related entities of importing and selling wet dry surface cleaning devices that allegedly infringed certain claims of two U.S. patents concerning surface cleaning apparatuses. After the complaint was filed with the United States International Trade Commission, Tineco introduced redesigned versions of the accused products, which were also evaluated for infringement. The key patent claims at issue involved limitations related to a battery charging circuit being disabled during a self-cleaning mode.An Administrative Law Judge (ALJ) at the International Trade Commission conducted an evidentiary hearing. The ALJ found that Tineco's original products infringed the asserted patent claims but that the redesigned products did not, as they did not meet the requirement that the battery charging circuit remain disabled during the automatic cleanout cycle. The ALJ also found that Bissell’s domestic industry products practiced the relevant claim limitations, and that all accused products met other disputed limitations. The Commission adopted the ALJ’s findings and issued a limited exclusion order barring importation of only the original infringing products.On appeal, in the United States Court of Appeals for the Federal Circuit, Bissell challenged the finding of non-infringement for the redesigned products, while Tineco cross-appealed on domestic industry findings and certain infringement determinations. The Federal Circuit affirmed the Commission’s Final Determination, holding that substantial evidence supported the findings that Tineco’s redesigned products did not infringe the relevant patent claims, that Bissell’s domestic industry products met the asserted limitations, and that the accused products satisfied the “brushroll within the recovery pathway” and “suction nozzle” limitations. The court affirmed the exclusion order for the original products and denied relief on all appeals. View "BISSELL, INC. v. ITC " on Justia Law

Enviro Tech Chemical Services, Inc. held a patent covering methods for treating poultry during processing, specifically by using peracetic acid to increase the weight of the poultry. The method involved several steps, including adjusting the pH of peracetic acid-containing water to a range described as “about 7.6 to about 10” by adding an alkaline source. Enviro Tech alleged that Safe Foods Corp. infringed upon various claims of this patent.The United States District Court for the Eastern District of Arkansas reviewed the case and conducted claim construction. Safe Foods argued that the terms “about” and “an antimicrobial amount” in the patent were indefinite. The district court agreed, finding both terms indefinite and holding the asserted claims invalid. The court entered judgment accordingly.On appeal, the United States Court of Appeals for the Federal Circuit examined whether the district court was correct in finding the term “about,” as used to define the pH range, indefinite. The Federal Circuit analyzed the claim language, the patent’s specification, and the prosecution history. The court found that the intrinsic record did not provide reasonable certainty to those skilled in the art about the scope of “about,” especially since the specification and prosecution history showed inconsistent and conflicting guidance regarding permissible pH deviations. Because the term “about” was indefinite, the Federal Circuit concluded that all asserted claims were invalid. The court therefore affirmed the judgment of invalidity entered by the district court. View "ENVIRO TECH CHEMICAL SERVICES, INC. v. SAFE FOODS CORP. " on Justia Law

A corporation owns a patent concerning systems and methods for providing access to shipment information using sensors, which can be attached to items for tracking and reporting data to a central location. The patent allows for customization and control over notifications about shipments, including limiting access to sensor information based on certain rules. Some claims of the patent specify restricting access by delaying when information is reported.Litigation began when the corporation sued another company for infringing this patent in the United States District Court for the District of Delaware. While the litigation was pending, a third party, who was not a defendant in the district court case, filed petitions with the Patent Trial and Appeal Board (PTAB) challenging some claims of the patent as obvious. The patent owner argued that the PTAB should not consider the petitions because the third party failed to identify all real parties in interest, specifically the company being sued, as required by statute. The PTAB disagreed, instituted review, and later denied a motion to terminate the proceedings for failure to name all real parties in interest. The PTAB issued a final written decision finding all challenged claims unpatentable as obvious.The United States Court of Appeals for the Federal Circuit reviewed the case. The court held that it lacked authority to review the PTAB’s refusal to determine whether all real parties in interest were named and its denial of the motion to terminate the proceedings, because such issues are barred from judicial review by statute. However, the appellate court found that the PTAB had erred in concluding that the patent owner had not contested one ground of obviousness and vacated the PTAB’s findings of obviousness for certain claims, remanding those issues for further proceedings. View "FEDERAL EXPRESS CORPORATION v. QUALCOMM INCORPORATED " on Justia Law