Justia Patents Opinion Summaries

Matthews manufactures cremation equipment, caskets, and bronze memorials for sale to funeral homes. Its Bio Cremation™ product, uses an alkaline hydrolysis process, as an environmentally friendly alternative to incineration, for cremation. Resomation granted Matthews an exclusive license to sell its alkaline hydrolysis equipment in the U.S. In 2007, Biosafe acquired one system and five method patents related to the application of alkaline hydrolysis to the disposal of various types of waste, such as medical waste, infectious agents, and hazardous materials. In 2011, Matthews sought a declaratory judgment of non-infringement, invalidity, and unenforceability of the patents and asserted state-law claims of trade libel, defamation, and tortious interference with contractual relations. Matthews alleged that Biosafe had wrongly accused Matthews of patent infringement, and made false accusations about Matthews to customers, potential customers, and employees. None of the Matthews units had yet been installed. The district court dismissed, finding that Matthews had not made “meaningful preparation” to conduct potentially infringing activity. Given that it had no information regarding the operating parameters of Matthews’ equipment, the court declined to provide “an advisory opinion.” The Federal Circuit affirmed. Matthews’ claims lacked sufficient immediacy and reality to support the exercise of declaratory judgment jurisdiction. View "Matthews Int'l Corp. v. Biosafe Eng'g, LLC" on Justia Law

The 772 application is directed to methods and compositions for recombining DNA in a eukaryotic cell (a cell with a nucleus), such as a human cell. The Board of Patent Appeals and Interferences affirmed rejection of independent claim 29 of the 772 application, as obvious over the combination of a patent and an article. Claim 29 covers a method of recombining DNA in a eukaryotic cell using modified versions of wild-type Int. The Federal Circuit affirmed. The disclosures provide substantial evidence that a person of ordinary skill in the art would have had a reasonable expectation of success for using the modified integrases disclosed in the article in place of wild-type Int in the method taught in the patent. View "In re Droge" on Justia Law

Outside the Box sought a declaratory judgment against Travel Caddy and its distributor. The district court held that Travel Caddy’s patent and its continuation patent are unenforceable in their entirety, based on inequitable conduct in the U.S. Patent and Trademark Office, consisting of failure to disclose that the parent patent was in litigation. The district court otherwise sustained the validity of some claims, but held the other claims of the patents invalid on ground of obviousness. The court held, on summary judgment, that the version of the Outside the Box tool carry case called the Electricians Carryalls infringes various patent claims, but that a modified version called Electricians Bag II and the tool carry case called Heavy-Duty ProTool Bag do not infringe. The court dismissed unfair-competition claims against Travel Caddy. The Federal Circuit reversed the judgment of unenforceability based on inequitable conduct, vacated the rulings of invalidity, affirmed the rulings of noninfringement, and remanded. View "Outside the Box Innovations, LLC v. Travel Caddy, Inc." on Justia Law

Medtronic sought a declaratory judgment of non-infringement and invalidity of reissue patents covering a cardiac resynchronization therapy device (previously called a biventricular pacer). The district court entered judgment of noniinfringement in favor of Medtronic and judgment of validity and enforceability in favor of the patent holder. The Federal Circuit vacated and remanded, holding that the district court relied on a legally incorrect allocation of the burden of proof to find non-infringement in the limited circumstances of the case and incorrectly construed the claim terms in question. View "Medtronic, Inc. v. Boston Scientific Corp." on Justia Law

The holder of the 946 Patent, “System and Apparatus for Interactive Multimedia Entertainment,” issued in 1995, alleged infringement. The district court found that, during prosecution of the 946 patent, the named inventor and his attorney withheld from the United States Patent and Trademark Office three material references and information about PTO rejections in two related prosecutions, thereby committing inequitable conduct and rendering the 946 Patent unenforceable. The Federal Circuit reversed, stating that there was no evidence of a deliberate decision to withhold the references. View "1ST Media, LLC v. Electronic Arts, Inc." on Justia Law

K-TEC, a company that manufactures and sells commercial blending equipment, owns U.S. Patents 117 842, which generally disclose and claim a blending system that contains a blending jar with a specific geometry. The benefit of the claimed geometry is that it alters the flow pattern of the liquid during blending in a way that reduces cavitation, which occurs when a pocket of air envelops the area surrounding the blender blade during blending. The 117 patent is the parent of the 842 patent. The district court concluded that the patents were not invalid, that two prior references were not analogous for purposes of showing obviousness, that Vita-Mix willfully infringed, and that K-TEC was entitled to about $11 million in reasonable royalty and lost profit damages. The Federal Circuit affirmed the decision as supported by the evidence. View "K-TEC, Inc. v. Vita-Mix Corp." on Justia Law

Santarus is the exclusive licensee of patents on formulations of benzimidazole proton pump inhibitors, a class of chemical compounds that inhibit gastric acid secretion and help prevent and treat stomach acid-related diseases and disorders. Santarus provides the PPI product omeprazole in formulations covered by the Phillips patents, brand name Zegerid. Par filed an Abbreviated New Drug Application (ANDA) for FDA approval to sell a generic counterpart of the Santarus Zegerid products, invoking the Hatch-Waxman Act (the Drug Price Competition and Patent Term Restoration Act of 1984), which established Paragraph IV certification, 21 U.S.C. 355(j)(2)(A)(vii)(IV), whereby an entity that seeks to market a generic counterpart of a patented drug product or method of use, before the patent has expired, may challenge the patent before actually marketing the drug. The district court found that Par’s ANDA products infringe the patents, but found all asserted claims invalid on the ground of obviousness, 35 U.S.C 103 and found certain claims invalid on the ground of inadequate written description, 35 U.S.C. 112. The district court held that there was not inequitable conduct by the inventor, his assignee, or their counsel in procuring the patents. The Federal Circuit reversed with respect to obviousness, but otherwise affirmed. View "Santarus, Inc. v. Par Pharma., Inc." on Justia Law

Mirror Worlds sued Apple, alleging direct and induced infringement of three patents directed to searching, displaying, and archiving computer files. The specification discloses a “document streaming” operating system that, unlike traditional operating systems, identifies documents with a time stamp instead of a file name and maintains them in chronologically ordered “streams.” Every document created and every document sent to a person or entity is stored in a main stream. The documents in the stream “can contain any type of data” including “pictures, correspondence, bills, movies, voice-mail and software programs.” By constantly keeping track of all the documents on the computer in these chronologically ordered streams and making the location and nature of file storage transparent to the user, the invention purportedly improves filing operations and enhances the quality of the user’s experience. The district court granted Apple judgment as a matter of law that Apple did not induce infringement. The jury found Apple liable for willfully infringing and awarded $208.5 million in damages. The court granted Apple’s motion for judgment as a matter of law, vacated the verdict, and concluded that Mirror Worlds failed to present substantial evidence of direct infringement and damages. The Federal Circuit affirmed. View "Mirror Worlds, L.L.C. v. Apple, Inc." on Justia Law

Akamai owns a method patent for delivery of web content, consisting of placing some of a provider’s content elements on a set of replicated servers and modifying the provider’s web page to instruct browsers to retrieve content from those servers. Akamai sued Limelight, alleging direct and indirect infringement. Limelight maintains a network of servers that places some content on its servers. Limelight does not modify content pages itself, but instructs customers on doing so. McKesson owns a method patent for electronic communication between healthcare providers and patients. McKesson alleged that Epic induced infringement. Epic licenses software that permits healthcare providers to communicate electronically with patients. Epic does not perform any steps of the patent; patients initiate communication and healthcare providers perform remaining steps. In the district court, Limelight and Epic were held not to infringe because they did not perform the steps in the method. The Federal Circuit reversed. When a single actor commits all elements of infringement, that actor is liable for direct infringement (35 U.S.C. 271(a)). When a single actor induces another to commit all elements of infringement, the first actor is liable for induced infringement (35 U.S.C. 271(b)). When the acts necessary to give rise to direct infringement are shared between actors, a single party may be liable for induced infringement. View "Akamai Tech., Inc. v. Limelight Networks, Inc." on Justia Law

LaserDynamics owns the 981 Patent, issued in 1996, directed to a method of optical disc discrimination that essentially enables an optical disc drive to automatically identify the type of optical disc (CD or DVD) inserted into the ODD. LaserDynamics entered into at least 29 licensing agreements from 1998 to 2003 for lump sum amounts of $1 million or less. QSI is a manufacturer of ODDs headquartered in Taiwan. QSI first sold its ODDs for integration into laptop computers in the U.S. in 2001. In 2002, LaserDynamics offered QSI a license under the 981 Patent, but QSI disputed whether its ODDs were within the scope of the patent and declined the offer. In 2006, LaserDynamics brought suit against QCI (a parent that manufactures laptop computers of QSI) and QSI for infringement. The Federal Circuit remanded regarding the damages owed by QCI pertaining to the infringing ODDs not purchased by QCI via specific suppliers, and for which QCI does not have an implied license to the 981 Patent. On remand, the hypothetical negotiation date shall be set in 2003. View "LaserDynamics, Inc. v. Quanta Computer, Inc." on Justia Law