Justia Patents Opinion Summaries

Rex Medical, L.P. and Intuitive Surgical, Inc. are competitors in the medical device industry, specifically in the market for surgical stapling products. Rex accused Intuitive of infringing U.S. Patent No. 9,439,650, which covers a system for stapling tissue during surgery. The accused products included several models of Intuitive’s SureForm staplers. Rex initially asserted two patents, but after Intuitive challenged one in an inter partes review, Rex withdrew it, leaving only the ’650 patent at issue. The dispute centered on claim 6 of the ’650 patent, which describes a stapling apparatus with specific structural features.The United States District Court for the District of Delaware presided over the case. Before trial, the court excluded Rex’s damages expert from testifying about a prior license agreement, finding the expert failed to apportion the value of the asserted patent from other patents in the agreement. At trial, neither party’s damages expert testified, and Rex relied on lay testimony regarding damages. The jury found Intuitive infringed claim 6 and that the claim was not invalid, awarding Rex $10 million in damages. After post-trial motions, the district court entered judgment for Rex on infringement and validity but reduced the damages award to $1, finding insufficient evidence to support the jury’s damages calculation and denying Rex’s request for a new trial on damages.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court’s rulings. The Federal Circuit held that the exclusion of Rex’s damages expert was proper because the expert did not adequately apportion the value of the asserted patent. The court also affirmed the reduction of damages to $1, finding the record lacked sufficient evidence for the jury to reasonably determine damages for the ’650 patent alone. The Federal Circuit further affirmed the district court’s findings on infringement and validity, rejecting Intuitive’s arguments regarding claim construction and written description. View "REX MEDICAL, L.P. v. INTUITIVE SURGICAL, INC. " on Justia Law

The dispute centers on allegations of intellectual property infringement involving shower curtains designed with embedded rings, eliminating the need for traditional hooks. The plaintiffs, a group of related companies, own several patents covering these “hookless” shower curtains, as well as registered and unregistered trademark and trade dress rights. The defendants, two companies that manufactured and sold similar shower curtains, were accused of infringing these patents, trademarks, and trade dress. The accused products featured rings with a flat upper edge and a slit, allowing the curtain to be attached to a rod without hooks.In the United States District Court for the Southern District of New York, the defendants’ motion to transfer venue was denied as untimely. The district court granted summary judgment of patent infringement in favor of the plaintiffs, based on its claim constructions, and precluded the defendants’ unclean hands defense for being raised too late. After a bench trial, the court found that the defendants infringed the asserted patents, the HOOKLESS® and EZ ON trademarks, and the claimed trade dress, and that some infringement was willful. The court awarded lost profits, reasonable royalties, attorneys’ fees, and costs.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the denial of the venue transfer and the exclusion of the unclean hands defense. However, it reversed the findings of infringement for the ’248 and ’609 patents as to one defendant, vacated the ’088 patent infringement finding as to that defendant, and affirmed the patent infringement findings as to the other. The court also vacated the trade dress infringement and willfulness findings, reversed the EZ ON trademark infringement finding, and vacated the HOOKLESS® trademark infringement finding. The award of attorneys’ fees was vacated, and the case was remanded for further proceedings consistent with these rulings. The court clarified the standards for claim construction, trade dress functionality, and standing to assert trademark rights. View "Focus Products Group International, LLC v. Kartri Sales Co." on Justia Law

Finesse Wireless LLC owns two patents related to methods for mitigating interference in radios caused by intermodulation products (IMPs), which can arise when radio signals interact with passive obstacles. Finesse alleged that AT&T Mobility LLC, by using a particular feature in Nokia radios, infringed specific claims of both patents. Nokia intervened in the case. The dispute centered on whether the accused radios performed the patented methods for reducing IMP interference, specifically whether they sampled the required signals and performed certain signal multiplications as described in the patent claims.The United States District Court for the Eastern District of Texas presided over a jury trial in which the jury found all asserted claims of both patents valid and infringed, awarding Finesse a lump-sum damages amount for the remaining life of the patents. After the verdict, AT&T and Nokia moved for judgment as a matter of law (JMOL) of noninfringement and for a new trial on damages, but the district court denied these motions.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL de novo, applying Fifth Circuit law. The Federal Circuit found that Finesse’s evidence, particularly its expert’s testimony, was insufficient and self-contradictory regarding whether the accused radios sampled both the “signals of interest” and “interference generating signals” as required by the first patent. For the second patent, the court determined that no reasonable jury could have found the accused radios performed the seven specific signal multiplications required by the claims. As a result, the Federal Circuit reversed the district court’s denial of JMOL of noninfringement for both patents and vacated the damages award. Costs were awarded to the defendants-appellants. View "FINESSE WIRELESS LLC v. AT&T MOBILITY LLC" on Justia Law

The dispute centers on a patent owned by a pharmaceutical company, which describes methods for reducing the risk of cardiovascular events in patients with coronary artery disease or peripheral artery disease by administering specific doses of rivaroxaban and aspirin. The patent claims include both general methods of administering these drugs and a particular claim involving a “first product” that combines both drugs in a single dosage form. The patent is based on results from a clinical trial known as COMPASS, which evaluated the efficacy and safety of this drug combination.Three generic drug manufacturers challenged the patent’s validity by filing petitions for inter partes review with the Patent Trial and Appeal Board (PTAB), arguing that the claims were anticipated or obvious in light of prior art references, including published articles describing similar drug regimens and ongoing clinical trials. The PTAB joined the proceedings and ultimately held that claims 1–2 were unpatentable as anticipated and claims 1–8 were unpatentable as obvious, relying on the prior art and its interpretation of the patent’s claim language.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the PTAB’s decision. The court affirmed the PTAB’s finding that claims 1–4 were unpatentable, holding that the phrase “clinically proven effective” in the claims, even if considered limiting, did not create a patentable distinction because it was functionally unrelated to the method itself. However, the court found that the PTAB had incorrectly construed the “first product” limitation in claims 5–8, which should require a single dosage form containing both drugs. The court vacated the PTAB’s unpatentability finding for claims 5–8 and remanded for further proceedings under the correct claim construction. The court affirmed in part, vacated in part, and remanded the case, with no costs awarded. View "BAYER PHARMA AKTIENGESELLSCHAFT v. MYLAN PHARMACEUTICALS INC. " on Justia Law

A patent owner brought two infringement lawsuits in the United States District Court for the Western District of Texas against a semiconductor company, alleging that certain integrated circuit products infringed three patents related to electronic circuitry and power-saving features. The accused products included specific chips that allegedly implemented a particular feature. After the lawsuits were filed, the defendant challenged the cases on grounds including improper service, lack of personal jurisdiction, and failure to state a claim. During the litigation, the plaintiff produced a licensing agreement with a third party, and subsequently entered into another agreement covering the accused products. Shortly thereafter, the plaintiff voluntarily dismissed both cases without prejudice.Following the dismissals, the defendant moved for attorneys’ fees, costs, and sanctions, arguing that the lawsuits were baseless. The district court denied the defendant’s motions for attorneys’ fees under 35 U.S.C. § 285, costs under Rule 54(d)(1), and sanctions under Rule 11 and 28 U.S.C. § 1927, but converted the voluntary dismissals to dismissals with prejudice as a sanction. The court also denied the defendant’s discovery requests related to confidentiality and access to certain materials.On appeal, the United States Court of Appeals for the Federal Circuit held that the district court erred in denying fees under § 285 and costs under Rule 54(d)(1), because the defendant became a prevailing party when the dismissals were converted to dismissals with prejudice. The Federal Circuit vacated those portions of the district court’s decision and remanded for further proceedings. The appellate court affirmed the district court’s denial of Rule 11 sanctions and fees under § 1927, finding no abuse of discretion. It also affirmed the denial of the remaining discovery request, concluding that the district court did not abuse its discretion in applying the protective order. The judgment was thus vacated in part, affirmed in part, and remanded. View "FUTURE LINK SYSTEMS, LLC v. REALTEK SEMICONDUCTOR CORPORATION " on Justia Law

A company developed and patented a process for desulfurizing heavy marine fuel oil (HMFO) to comply with international sulfur content standards. The patented process involves taking a high-sulfur HMFO that meets certain physical property requirements and then hydroprocessing it to reduce its sulfur content. The company marketed its technology to various refineries, including the defendants, but no licensing agreement was reached. The defendants later modified their refineries to produce low-sulfur HMFO, prompting the plaintiff to sue for patent infringement, specifically alleging that the defendants’ processes at one refinery infringed two claims of the relevant patent.In the United States District Court for the Southern District of Texas, the parties disputed the proper construction of certain claim terms and the appropriate method and location for testing the fuel’s compliance with the required standards. During discovery, the defendants argued that it was too dangerous to obtain certain test samples, and the court accepted their position, allowing the plaintiff to use an estimation formula instead. On the eve of trial, however, the defendants introduced a new noninfringement theory, arguing that only actual test data—not estimates—could prove compliance. The district court allowed this argument, and the jury returned a general verdict of noninfringement. The district court later found the defendants’ argument improper and prejudicial but deemed the error harmless and denied the plaintiff’s motion for a new trial.The United States Court of Appeals for the Federal Circuit reviewed the case. It held that the district court abused its discretion in finding the error harmless because the jury’s general verdict made it impossible to determine whether the improper argument affected the outcome. The appellate court reversed the denial of a new trial and remanded for further proceedings, also affirming the district court’s construction of the disputed claim term. View "MAGEMA TECHNOLOGY LLC v. PHILLIPS 66 " on Justia Law

Global Health Solutions LLC and Marc Selner each filed patent applications in August 2017 for a method of preparing a wound treatment ointment containing nanodroplets of an aqueous biocide suspended in petrolatum jelly without emulsifiers. Selner filed his application four days before GHS, making him the first-filer under the America Invents Act (AIA) “first-inventor-to-file” system. GHS alleged that its founder, Bradley Burnam, conceived the invention and communicated it to Selner, who then derived the invention and filed first. Both parties agreed that their applications claimed the same invention, and the dispute centered on who conceived the invention and when.The United States Patent and Trademark Office, Patent Trial and Appeal Board (the Board) instituted a derivation proceeding. After reviewing evidence, including contemporaneous emails, the Board found that Burnam communicated the invention to Selner by 4:04 p.m. on February 14, 2014, but also found that Selner had independently conceived the invention earlier that same day, by 12:55 p.m. The Board determined that Selner did not derive the invention from Burnam and ruled in favor of Selner. GHS appealed, arguing that the Board erred in its evidentiary rulings, burden of proof allocation, and failure to require reduction to practice for conception, and also requested that Burnam be named a co-inventor.The United States Court of Appeals for the Federal Circuit reviewed the Board’s legal conclusions de novo and factual findings for substantial evidence. The court held that the Board’s focus on “first-to-invent” was harmless error, as Selner’s independent conception was dispositive under the AIA. The court found no reversible error in the Board’s evidentiary rulings, burden allocation, or treatment of reduction to practice. The court also held that GHS failed to properly preserve its request for correction of inventorship. The Board’s judgment for Selner was affirmed. View "GLOBAL HEALTH SOLUTIONS LLC v. SELNER " on Justia Law

The case concerns two patents related to methods for preparing DNA samples for sequencing, owned by Laboratory Corporation of America Holdings, Labcorp Genetics, Inc., and The General Hospital Corporation. The patents describe techniques for enriching specific regions of DNA to make sequencing more efficient, using various types of primers and adaptors. The dispute centers on whether certain DNA preparation kits sold by Qiagen and its affiliates infringe these patents, specifically regarding the design and function of the primers used in Qiagen’s kits.After the plaintiffs filed suit in the United States District Court for the District of Delaware, alleging infringement of both patents, the case proceeded to a jury trial. The jury found that Qiagen willfully infringed the asserted claims of both patents—under the doctrine of equivalents for one patent and literally for the other—and awarded the plaintiffs approximately $4.7 million in damages. The district court denied Qiagen’s renewed motion for judgment as a matter of law (JMOL) on non-infringement, invalidity, and damages, and also denied Qiagen’s alternative request for a new trial.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL de novo. The Federal Circuit held that there was insufficient evidence to support the jury’s findings of infringement for either patent. The court determined that the district court erred in allowing the jury to interpret the claim term “identical” as “identical to a portion,” and found that the evidence did not support infringement under the doctrine of equivalents or literal infringement as required by the patent claims and their constructions. As a result, the Federal Circuit reversed the district court’s denial of JMOL of non-infringement for both patents, and remanded with instructions to grant JMOL of non-infringement. View "LABORATORY CORPORATION OF AMERICA HOLDINGS v. QIAGEN SCIENCES, LLC " on Justia Law

The dispute centers on a patent for a system that automates the adjustment of selectorized dumbbells using an electric motor. The patent describes a dumbbell with stacks of weight plates on each side, a handle, and a movable selector that, when positioned, couples different numbers of plates to the handle. The innovation lies in using an electric motor, operatively connected to the selector, to move it into the desired position based on user input, thereby automating the weight selection process and addressing safety and convenience issues present in prior manual systems.The United States District Court for the District of Utah reviewed the case after the defendant moved to dismiss the complaint, arguing that the asserted patent claims were ineligible under 35 U.S.C. § 101. The district court applied the Supreme Court’s two-step framework for patent eligibility and determined that all but one claim (claim 19) were directed to an abstract idea and implemented using generic components, thus failing the eligibility test. The court granted the motion to dismiss as to claims 1–18 and 20, but denied it for claim 19, finding that the parties had not sufficiently addressed its eligibility.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the district court’s decision de novo. The Federal Circuit held that the relevant claims were not directed to an abstract idea but instead to a specific mechanical improvement in selectorized dumbbells. The court found that the claims recited a sufficiently specific structure and method, including the use of an electric motor to automate weight selection, and thus did not preempt all forms of automated weight adjustment. The Federal Circuit reversed the district court’s dismissal of claims 1–18 and 20 and remanded the case for further proceedings. View "POWERBLOCK HOLDINGS, INC. v. IFIT, INC. " on Justia Law

The dispute centers on allegations by Mondis Technology Ltd. and related entities that LG Electronics Inc. and its U.S. subsidiary infringed claims 14 and 15 of U.S. Patent No. 7,475,180. The patent describes a display unit, such as a computer monitor, that stores identification numbers in memory to control access by external devices. The key issue was whether the patent’s written description supported a claim limitation requiring an “identification number for identifying at least a type of said display unit,” as opposed to identifying a specific unit.After Mondis filed suit in the Eastern District of Texas, the case was transferred to the United States District Court for the District of New Jersey and stayed for patent reexamination. When some claims survived, litigation resumed on claims 14 and 15. A jury found the claims not invalid and infringed, awarding damages to Mondis. The district court denied LG’s motion for judgment as a matter of law (JMOL) on invalidity, relying on the presumption of validity and the jury’s ability to weigh expert testimony. The court vacated the initial damages award and ordered a retrial, after which a reduced damages award was entered. Both parties appealed.The United States Court of Appeals for the Federal Circuit reviewed the district court’s denial of JMOL. The appellate court held that no reasonable jury could find the patent’s written description adequately supported the claim limitation requiring identification of a type of display unit. The court found that the patent only disclosed identification of specific units, not types, and that neither expert testimony nor the prosecution history provided substantial evidence to the contrary. The Federal Circuit reversed the district court’s judgment, held claims 14 and 15 invalid for lack of written description, and ordered judgment for LG. All other issues were deemed moot. View "Mondis Technology Ltd. v. LG Electronics Inc." on Justia Law