Justia Patents Opinion Summaries

This case concerned a patent for an innovative deep fryer designed by respondent SEB S.A. ("SEB"), a French maker of home appliances. SEB sued Pentalpha Enterprises, Ltd. ("Pentalpha"), a Hong Kong home appliance maker and wholly owned subsidiary of petitioner Global-Tech Appliances, Inc., asserting that it had contravened 35 U.S.C. 271(b) by actively inducing Sunbeam Products, Inc. ("Sunbeam") and the other purchasers of Pentalpha fryers to sell or offer to sell them in violation of SEB's patent rights. At issue was whether a party who "actively induces infringement of a patent" under section 271(b) must show that the induced acts constituted patent infringement. The Court held that induced infringement under section 271(b) required knowledge that the induced acts constituted patent infringement and that deliberate indifference to a known risk that a patent existed did not satisfy the knowledge required by section 271(b). The Court, nevertheless, affirmed the judgment of the Court of Appeals because the evidence in this case was plainly sufficient for a jury to find that Pentalpha subjectively believed there was a high probability that SEB's fryer was patented, that Pentalpha took deliberate steps to avoid knowing that fact, and that it therefore, willfully blinded itself to the infringing nature of Sunbeam's sales.

Companies sought a declaratory judgment of non-infringement of patents on diabetes testing products; the patent-holder claimed infringement. The district court found no infringement of two patents, found that several claims in one patent were anticipated, and found another patent (551) unenforceable due to obviousness and inequitable conduct. The Federal Circuit affirmed. With respect to patent 551, there was ample evidence to support a finding of intent to deceive the Patent Office in failing to disclose highly material statements made during revocation proceeding on a European patent. There was also ample evidence to support findings of non-infringement and of anticipation.

The holder of patents on an FDA-approved product that promotes eyelash growth claimed patent infringement and violation of California Business & Professions Code 17200 unfair competition provisions against companies marketing similar products. The district court dismissed the state law claims for lack of standing under an amendment to that law, enacted by the voters as Proposition 64. The Federal Circuit reversed and remanded. The complaint adequately alleged economic injury caused by defendants' unfair business practices; it is not necessary that the plaintiff had direct business dealings with the defendants.

Appellants appealed from an order of the district court denying its motion, made after a preliminary injunction was vacated by the court, to recover damages against an injunction bond posted by appellee. At issue was whether the district court correctly concluded that the damages sought were not proximately caused by the injunction, and that, in deciding this issue, the district court should have applied a presumption in favor of recovery against the bond. The court held that a wrongfully enjoined party was entitled to a presumption in favor of recovery against an injunction bond and that the district court's decision was insufficient to permit meaningful appellate review. Accordingly, the court vacated the order and remanded for reconsideration and clarification.

The company filed a claim under the Tariff Act of 1930, 19 U.S.C. 1337, asserting infringement of its patents on microchip encapsulation innovations. The ITC found no violation. The Federal Circuit affirmed. Substantial evidence supported the finding of no infringement of one patent by 17 of 18 defendants. The court also affirmed the ITC's determination that the patent was not anticipated and its finding of patent exhaustion with respect to the eighteenth defendant. The claims with respect to other patents, which have expired, are moot.

Plaintiff develops and manufactures cable telephony and data products for cable system operators for use in Voice over Internet Protocol systems and sought a declaratory judgment that its customer did not infringe defendant's patents by using equipment purchased from plaintiff. The district court dismissed for lack of subject matter jurisdiction. The Federal Circuit reversed and remanded. Although economic injury alone is insufficient to create standing, the defendant's accusation of infringement against plaintiff's customer included an implicit assertion that plaintiff indirectly infringed or contributed to infringement of the patent. The defendant has not provided plaintiff with a covenant not to sue.

Allergan has various patents that protect its glaucoma drug. The defendants each filed an Abbreviated New Drug Application (ANDA) seeking permission from the FDA to market a generic version of the drug. The district court found that Allerganâs asserted patents were not invalid and that the defendants infringed those patents. With respect to one defendant, the Federal Circuit reversed on one claim as "obvious" and affirmed the injunction with respect to four other claims. The court reversed with respect to the other defendant, stating that it would not assume that the company would violate its ANDA and that compliance with the ANDA would not result in infringement.

In litigation concerning patents covering various aspects of dynamic random access memory (DRAM) to minimize the bottleneck in the ability of computers to process data through memory and synchronous dynamic random access memory (SDRAM), the other type of new memory technology, the district court upheld the defendant's patents and found infringement. In parallel litigation, the district court had concluded that the defendant had spoliated documents in contravention of a duty to preserve because litigation was reasonably foreseeable prior to the defendant's second document shred day; in that case, the Federal Circuit upheld the determination of spoliation, but remanded with respect to the sanction. In this case, the Federal Circuit remanded for reconsideration of the spoliation issue, but affirmed the court's construction of the term "bus" and its determinations that the defendant had not waived its right to litigate and concerning adequacy of written description and obviousness. Applying the proper standard compels a finding that the litigation was reasonably foreseeable. The destruction of the documents could reasonably constitute a crime, so piercing the attorney-client privilege, as in the parallel case, is appropriate.

Patents issued to Rambus covered various aspects of dynamic random access memory (DRAM)to minimize the bottleneck in the ability of computers to process data through memory. Rambus initially believed the patents broad enough to encompass synchronous dynamic random access memory (SDRAM), the other type of new memory technology, but later amended its applications to cover SDRAM. Micron claimed that its production of SDRAM products did not infringe Rambusâs patents and that Rambusâs patents were invalid and violated antitrust laws. The district court held that the patents were unenforceable against Micron because Rambus had engaged in spoliation by intentionally destroying relevant, discoverable documents in derogation of a duty to preserve them and did not reach the validity of the patents. The Federal Circuit affirmed with respect to spoiliation, vacated in part, and remanded. The district did not explain why only dismissal would vindicate the aims of deterring future spoliation; protecting the defendants' interests; and remedying the prejudice defendants suffered as a result of Rambusâs actions.

The Board of Patent Appeals and Interferences affirmed the rejection of claims related to controlled-release tablets containing the opioid narcotic oxymorphone as obvious. The Federal Circuit upheld two rejections, stating that secondary considerations did not compel a holding of nonobviousness, and vacated a third as not supported by substantial evidence.