Justia Patents Opinion Summaries

Apple has multiple patents for features of the iPhone and, in 2012, sued Samsung, alleging infringement of five patents directed to smartphone and tablet interfaces. The district court held on summary judgment that Samsung infringed the 172 patent. A jury found that nine Samsung products infringed one or both of Apple’s 647 and 721 patents and awarded a total of $119,625,000. Apple sought a permanent injunction to bar Samsung from making, using, selling, developing, advertising, or importing software or code capable of implementing the infringing features in its products, with a 30-day “sunset period” that would stay enforcement of the injunction until 30 days after it was entered , during which Samsung could design around the infringing features. The district court denied Apple’s motion. The Federal Circuit vacated, Although the evidence may not make a strong case of irreparable harm, Apple satisfied the causal nexus requirement and therefore established irreparable harm. Apple also established that the harm it will suffer is not easily compensable at law. As the district court found, the balance of hardships and public interest weigh strongly in favor of an injunction. View "Apple, Inc.. v. Samsung Elecs. Co., Ltd." on Justia Law

Astornet alleges that it is sole exclusive licensee and owner of all rights in the 844 patent, issued in 2009 to Haddad as the inventor and entitled “Airport vehicular gate entry access system” and asserted the patent against NCR, MorphoTrust USA, and BAE Astornet alleged that the three had contracts with the Transportation Security Administration (TSA) to supply boarding-pass scanning systems; that TSA’s use of the equipment infringed and would infringe the patent; and that NCR and MorphoTrust were bidding for another contract to supply modified equipment whose use by TSA would also infringe. The Federal Circuit affirmed dismissal, finding that Astornet’s exclusive remedy for the alleged infringement was a suit against the government in the Court of Federal Claims under 28 U.S.C. 1498. View "Astornet Techs., Inc. v. BAE Sys., Inc." on Justia Law

R+L claimed infringement of the 078 patent, which generally relates to an improved method of consolidating freight into trailers to optimize delivery efficiencies for the loads in each trailer. While the case was pending, R+L filed for ex parte reexamination of the patent. Although the patent survived, R+L added language to all of the claims at issue. Because the district court determined that the new claims were not substantially identical to the initial claims of the 078 patent, and because there was no dispute that Qualcomm ceased its allegedly infringing activity before the reexamination certificate issued, R+L stipulated to final judgment, dismissing its infringement claim against Qualcomm. R+L appealed the determination that the amendments made during reexamination resulted in a substantive change in claim scope. The Federal Circuit affirmed, finding that amended claim 1 is not “substantially identical” to original claim under 35 U.S.C. 252, so R+L is not entitled to infringement damages prior to issuance of the reexamination certificate. View "R+L Carriers, Inc.. v. Qualcomm, Inc." on Justia Law

Magnetar filed suit alleging that Intamin maliciously prosecuted a patent infringement action against it and claiming that Intamin prosecuted the action even though the ‘350 Patent was invalid pursuant to the on-sale bar of 35 U.S.C. 102 (on-sale bar). The district court granted summary judgment to Intamin. The court concluded that a reasonable attorney could have determined that the on-sale bar did not apply due to the genuine dispute concerning whether the magnetic braking system had been (1) offered for sale before the critical date; and (2) was ready for patenting before the critical date. Therefore, the court affirmed as to this issue. The court also affirmed the district court's conclusion that Magnetar has not alleged sufficient facts to show a causal antitrust injury stemming from Intamin’s actions. Finally, the court concluded that the district court properly refused to sanction Magnetar for filing a frivolous action where Magnetar proceeded in good faith in not admitting facts related to the antitrust injury. Accordingly, the court affirmed the district court's judgment in its entirety. View "Magnetar Techs. v. Intamin, Ltd." on Justia Law

The three patents at issue share the same written description and explain that medical implements, such as catheters and luer ports, are common sites for transmissions of pathogens into patients. To prevent such transmissions, medical staff traditionally swabbed a site before making connections to medical implements. Swabs came in a small pad of cotton gauze soaked in a cleaning agent (e.g., isopropyl alcohol) and packed in a foil package to prevent evaporation. After swabbing, the site is allowed to dry, killing any pathogens. In practice, these swabbing procedures were often “overlooked” or “poorly executed.” The inventors provided a cleaning device that includes a cap that twist on to the medical implements and, when used, reliably disinfects a medical implement. In an infringement suit, the district court granted summary judgment of invalidity, finding the asserted claims obvious under 35 U.S.C. 103. The Federal Circuit reversed. The patent holder established a genuine dispute over whether one of ordinary skill in the art would have been motivated to add a vent to the disinfecting cap described in prior art. View "Ivera Med. Corp. v. Hospira, Inc." on Justia Law

National Graphics owns the 196 patent, which is directed to making molded plastic articles bearing a “lenticular” image. The patent issued in 2003, from an application filed in 2000. Dynamic petitioned the Patent and Trademark Office for inter partes review of the patent, arguing that claims 1, 8, 12, and 14 were anticipated by the Raymond patent. The Patent Trial and Appeal Board declined to reject two of the claims under 35 U.S.C. 102(e) and found that National Graphics reduced to practice its invention by March 28, 2000, before the May 5, 2000 filing date of the Raymond patent. The Federal Circuit affirmed. Dynamic failed to carry its burden of proving unpatentability. View "Dynamic Drinkware, LLC v. Nat'l Graphics, Inc." on Justia Law

Media Rights sued Capital One, alleging infringement of its patent, entitled “Method of Controlling Recording of Media.” The patent prevents unauthorized recording via a compliance mechanism, which diverts incoming media content protected by law or agreement from being output from a system in order to stop the illegal copying or sharing of that content. The district court found that all claims were invalid for indefiniteness. The Federal Circuit affirmed, upholding a determination that the term “compliance mechanism,” which is a limitation in every single claim, is a means-plus-function term that lacks sufficient structure. View "Media Rights Techs, Inc. v. Capital One Fin. Corp." on Justia Law

Dome owns a patent for making contact-lens materials that are rigid and gas permeable. On reexamination, the U.S. Patent and Trademark Office found that the claimed method at issue was obvious and therefore unpatentable. The district court found that a person of ordinary skill would have been motivated to combine the prior art and that the prior art did not teach away from the claimed invention, so that the claims were unpatentable under 35 U.S.C. 103. The court found that Dome’s proffered evidence of objective indicia did not indicate nonobviousness. The Federal Circuit affirmed. View "Dome Patent L.P. v. Lee" on Justia Law

In 2005, Dow sued NOVA, alleging infringement of claims of patents covering ethylene polymer compositions (a type of plastic) with improved modulus, yield strength, impact strength, and tear strength. These polymers can be made into films that can be down-gauged (made thinner) without losing strength. A jury found the asserted claims to be infringed and not invalid. The Federal Circuit affirmed, holding that the asserted claims were not indefinite. The district court granted supplemental damages in the form of lost profits and reasonable royalties and denied Dow’s request for enhanced damages. Subsequently, the Supreme Court decided Nautilus v. Biosig Instruments (2014), establishing a new standard: “a patent is invalid for indefiniteness if its claims, read in light of the specification delineating the patent, and the prosecution history, fail to inform, with reasonable certainty, those skilled in the art about the scope of the invention. The Federal Circuit then held that the intervening change resulting from Nautilus provides an exception to the doctrine of law of the case or issue preclusion. Reviewing the supplemental damages award, the court evaluated the indefiniteness of the claims under the Nautilus standard, held that the claims are indefinite, and reversed the award of supplemental damages. View "Dow Chem. Co. v. NOVA Chems. Corp." on Justia Law

Inline’s patented products are plastic food containers with tamper-evident and tamper-resistant features. The containers have a hinged plastic bridge between the top and bottom portions of the container, the bridge having a frangible section that must be severed in order to open the container, so that tampering or opening of the container is readily evident. Inline sued EasyPak for infringement. Following claim construction, Inline moved for entry of final judgment of non-infringement of its 003 patent, on the premise that the claims as construed are not infringed and granted EasyPak a covenant not to sue on the 680 patent. The district court then entered final judgment of non-infringement of the 003 patent, dismissed without prejudice EasyPak’s declaratory judgment counterclaims for invalidity, and dismissed Inline’s count for infringement of the 680 patent with prejudice. The Federal Circuit vacated, holding that the terms “frangible section” and “tamper evident bridge” were incorrectly construed with respect to the 003 patent. The district court erred in limiting the claims to a specific embodiment, for the invention as claimed is supported by the patent’s broader disclosure. View "Inline Plastics Corp.. v. Easypak, LLC" on Justia Law