Justia Patents Opinion Summaries

Plaintiff sued defendant alleging that defendant misappropriated plaintiff's trade secrets related to a meat-packing method, which used a zero parts-per-million oxygen-storage atmosphere, after plaintiff visited defendant's plant to demonstrate its meat-packing method. At issue was whether the district court considered plaintiff's affidavit on reconsideration and whether defendant's motion for summary judgment was properly granted. The court held that the district court properly considered plaintiff's objected-to evidence when ruling on its motion for consideration; that the district court erred by entering summary judgment in favor of defendant when it incorrectly defined plaintiff's trade secrets and failed to consider that a unique combination of elements already publicly disclosed or generally known were protectable as trade secrets under Texas law; and that the district court properly denied plaintiff's partial summary judgment claim on the existence of a fiduciary duty and did not err when it failed to sua sponte enter judgment in plaintiff's favor.

The companies sell the parts of beverage cans. Crown sued Ball concerning two patents issued to Crown in 2005. The district court entered summary judgment for Ball. The Federal Circuit reversed and remanded, first holding that the patents did not violate the written description requirement. The common specification of the patents conveyed, to one of ordinary skill in the art, that Crown was in possession of an embodiment that improved metal usage. There remained a material issue of fact as to whether the patents claimed improvements inherently anticipated by a prior patent application, so summary judgment was inappropriate.