Justia Patents Opinion Summaries

The patent describes an infusion system used to meter and deliver fluids from multiple sources into a patient's body. Different fluids may be discharged at different rates using a central control device. Ergo sued CareFusion for infringement of several of the patent's claims; the parties stipulated that several terms were means-plus-function terms, including the terms "programmable control means" and "control means." The parties agreed that the analysis for both terms is the same and that the function for the terms is "controlling the adjusting means." The district court held that the "control means" terms are indefinite for failure to disclose corresponding structure. The Federal Circuit affirmed. View "Ergo Licensing, LLC v. CareFusion 303, Inc." on Justia Law

The patent claims at issue covered processes that help doctors who use thiopurine drugs to treat patients with autoimmune diseases determine whether a given dosage level was too low or too high. The claims purported to apply natural laws describing the relationships between the concentration in the blood of certain thiopurine metabolites and the likelihood that the drug dosage would be ineffective or induce harmful side-effects. At issue was whether the claimed processes have transformed these unpatentable natural laws into patent-eligible applications of those laws. The Court concluded that they have not done so and that therefore the processes were not patentable. The steps in the claimed processes involved well-understood, routine, conventional activity previously engaged in by researchers in the field. At the same time, upholding the patents would risk disproportionately tying up the use of the underlying natural laws, inhibiting their use in the making of further discoveries. Therefore, the Court reversed the judgment of the Federal Circuit. View "Mayo Collaborative Services v. Prometheus Laboratories, Inc." on Justia Law

The patents are directed to regulating access to content that is delivered through a computer network. Digital-Vending sued three businesses involved in online education, alleging infringement. The district court issued a claim construction order. Two defendants entered into settlements. The third, University of Phoenix, sought summary judgment of non-infringement. Digital-Vending filed a motion for reconsideration of construction of the term "registered user." The district court granted for summary judgment of non-infringement and entered judgment in favor of Phoenix. The Federal Circuit vacated in part, finding that the determination was based on erroneous construction, and affirmed in part. View "Digital-Vending Servs. Int'l, LLC v. Univ. of Phoenix, Inc." on Justia Law

MySpace, FOX, and Craigslist sought declaratory judgment that certain patents owned by GraphOn were invalid and not infringed by plaintiffs. The patents related to the ability to create, modify, and store database records over a computer network. The District Court granted plaintiffs summary judgment. The Federal Circuit affirmed. The district court's claim construction of "database" was reasonable and supported by the context; its overall conclusion that the claims were anticipated or obvious was appropriate. The case was properly decided under sections 102 and 103 of the Patent Act and not under section 101. View "MySpace, Inc. v. Graphon Corp." on Justia Law

The Board of Patent Appeals and Interferences declared an interference between the claims of a patent belonging to Pioneer and those of a pending application owned by Monsanto. The claims concern transgenic corn. After the Board concluded that Monsanto was not time-barred under 35 U.S.C. 135(b)(1) and that its claims were entitled to seniority, Pioneer stipulated to judgment against it and the Board canceled Pioneer's claims. The Federal Circuit affirmed. View "Pioneer Hi-Bred Int'l, Inc. v. Monsanto Tech., LLC" on Justia Law

Defendant's patent discloses an investment tool designed to enable property owners to buy and sell properties without incurring tax liability by enabling like-kind exchanges under 26 U.S.C. 1031. The claims require aggregation of multiple properties into a portfolio; interests in the portfolio are divided into "deed shares" and sold to investors similar to the sale of stock. Each deedshare can be encumbered by its own mortgage. The patent allows for a master tenant to perform administrative tasks such as paying insurance, property taxes, and rents. The district court invalidated each of 41 claims in the patent for failing to claim patent-eligible subject matter under 35 U.S.C.101, reasoning that the claims were not tied to a particular machine or apparatus and that none of the claims transform any article to a different state or thing. The Federal Circuit affirmed, holding that the claims attempt to capture unpatentable abstract subject matter. View "Fort Props., Inc. v. Am. Master Lease, LLC" on Justia Law

The 690 patent is directed to a process for clarifying low alkalinity water using a blend of a high molecular weight quaternized polymer and an aluminum polymer. Claim 1 refers to a process for clarification of water of "raw alkalinity less than or equal to 50 ppm by chemical treatment." A jury found that the 690 patent was valid and indirectly infringed. The Federal Circuit reversed in part, holding that the verdict that the 690 patent was not invalid under 35 U.S.C. 102 was not supported by substantial evidence.The court affirmed that defendant did not misappropriate the trade secret described in claim 1. View "ClearValue, Inc. v. Pearl River Polymers, Inc." on Justia Law

The technology involves prosthetic vascular grafts, fabricated from highly-expanded polytetrafluoroethylene, and used to bypass or replace blood vessels to assure adequate and balanced blood flow to particular parts of the body. The 135 patent application was filed in 1974, but the patent did not issue until 2002. The district court found that the patent had been willfully infringed and was not invalid for improper inventorship, anticipation, obviousness, or lack of written description, and awarded enhanced damages, attorneys' fees and costs, and an ongoing royalty. The Federal Circuit affirmed, finding substantial evidence to support the jury verdict. View "Bard Peripheral Vascular, Inc. v. W.L. Gore & Assocs., Inc." on Justia Law

The 547 and 052 patents relate to technology for weighing objects, such as large commercial trucks. Mettler sued B-Tek alleging infringement of certain claims of the patents. The district court construed the claims and the jury found that B-Tek did not infringe any of the asserted claims and that the asserted claims of the 052 patent would have been obvious. The Federal Circuit affirmed, holding that the court correctly construed the claims, particularly: "circuit means associated with said counterforce, said circuit means being responsive to external control," "means for producing digital representations of loads applied to said counterforce," and "means for transmitting said digital representations." Substantial evidence supported the verdict. The court properly denied sanctions for Mettler's alleged withholding and destruction of documents; the documents were not highly relevant.View "Mettler-Toledo, Inc. v. B-TEK Scales, LLC" on Justia Law

Plaintiffs accused Sony and Sony entities of infringing claims of a patent relating to a tactile feedback system for computer video games. The district court construed disputed claim terms and the parties stipulated to a judgment of noninfringement. The Federal Circuit vacated and remanded, finding that the district court improperly limited the term "attached to said pad" to mean attachment only to an external surface and erred in its construction of the term "flexible." View "Thorner v. Sony Computer Entm't Am., LLC" on Justia Law