Justia Patents Opinion Summaries

The patent concerns blood glucose monitoring systems, used by individuals with diabetes. Such systems typically consist of an electrochemical meter and disposable test strips onto which the user places a drop of blood. The strip contains “working electrodes” or “reference electrodes,” that connect to the meter during operation. Each working electrode is coated with an enzyme and a mediator. The enzyme reacts with glucose in the blood sample, releasing electrons. The mediator then transfers those electrons to the working electrode, which is connected to the meter, which measures the resulting electric current to determine blood glucose level. Meters and test strips of this general design became available in the 1980s. LifeScan’s patent claims to improve earlier systems with a method of comparing measurements from separate working electrodes. Significant differences in the readings of the working electrodes indicate problems such as inadequate sample volume or manufacturing defects, and the readings are to be discarded. A reference electrode on the strip serves as a common reference for both working electrodes. LifeScan manufactures such a system, the “OneTouch Ultra” and claimed infringement by defendant. The district court found likely infringement and entered an injunction. The Federal Circuit reversed, finding that defendant established a patent exhaustion defense. View "Lifescan Scotland, Ltd. v. Shasta Tech., LLC" on Justia Law

Probe cards are used to test chips on semiconductor wafers. Probes have tips that make contact with bonding pads on the periphery of each chip, initially pierce the oxide layer atop the conductive layer of the bonding pad, then are moved along the pads to a second position to create a reliable electrical contact, leaving a “scrub mark” on the bonding pad in the process. ITC sued Rudolph for infringement of the patent, which discloses a digital viewing system to assess whether probes have become misaligned relative to each other by predicting the length and location of scrub marks. The system includes a camera under a viewing window that obtains the three-dimensional coordinates of the probe tips in first and second states. The district court entered summary judgment, finding infringement. The Federal Circuit reversed in part and affirmed in part. Prosecution history estoppel precludes the application of the doctrine of equivalents and a willfulness finding predicated on that judgment and a corresponding award of enhanced damages must, therefore, be vacated. The court affirmed the award of damages for literal infringement.View "Integrated Tech. Corp. v. Rudolph Tech., Inc." on Justia Law

FG and Randall are competitors, selling products for refrigerated trucks. Both parties manufacture moveable, track-mounted bulkheads (partitions) for dividing cargo space. FG’s patent, issued in 2007, discloses partitioning apparatuses that include two half-width panels independently mounted on the ceiling of the shipping container by rail-and-trolley assemblies, so that panels can be strapped together to form a full-width partition, separately moved along the container’s length for separate positioning or raised and stowed against the ceiling. Randall requested inter partes reexamination of the patent, and the Patent and Trademark Office examiner rejected a number of FG’s claims as obvious over a combination of prior-art references. The Board of Patent Appeals and Interferences reversed, unable to discern any reason that one of ordinary skill in the art would have been motivated to combine the cited references. The Federal Circuit vacated, stating that the Board failed to consider a wealth of well-documented knowledge that is highly material to evaluating the motivation to combine references to arrive at the claimed invention.View "Randall Mfg. v. Rea" on Justia Law

Synthes filed suit, alleging that SK’s M6-C and M6-L intervertebral implants infringed claims of a Synthes patent that is directed to an “Intervertebral Implant,” a prosthetic device designed to replace a diseased or degenerated disc located between adjacent vertebrae of the human spine. The Synthes patent originated from a German language Patent Cooperation Treaty application filed in 2003. The asserted claims were added by amendment in 2008. A jury found that SK’s implants did not infringe the asserted claims and that the claims were invalid for lack of written description. The Federal Circuit affirmed both the finding of invalidity and the district court’s denial of SK’s request for attorneys’ fees.View "Synthes USA LLV v. Spinal Kintetics, Inc." on Justia Law

The Ibormeith patent, entitled “Sleepiness Detection for Vehicle Driver or Machine Operator,” concerns the monitoring a vehicle driver’s sleepiness and issuing a warning to the driver. The monitor disclosed in the patent may take into account factors including natural body-clock (circadian) rhythm, the magnitude and number of corrective steering actions the driver takes, cabin temperature, monotony of the road, and how long the driver has been driving. Some factors involve actions or conditions at the moment, like steering and light conditions, which are measured by sensors in the vehicle. Others involve general or driver-specific background information, such as circadian rhythm or a driver’s recent sleep patterns and alcohol consumption, which must be input by other means (the programmer or driver). The factors are weighted, according to contributory importance, and combined in a computational decision algorithm or model, to provide a warning indication of sleepiness. The claims at issue contain a “computational means” element that is subject to 35 U.S.C. 112(f). Ibormeith sued Mercedes for infringement. Mercedes argued that the means-plus-function “computational means” limitations in two independent claims were indefinite. The district court entered summary judgment in favor of Mercedes. The Federal Circuit affirmed, noting that the specification does not contain an algorithm that adequately provides structure for the claimed functions. View "Ibormeith IP, LLC v. Mercedes-Benz USA" on Justia Law

The patent examiner rejected claims in an application directed to a bone screw with a shank that is easy to produce and eliminates the need for an additional element to avoid splaying. The Patent Trial and Appeals Board affirmed. The Federal Circuit vacated on the basis that the examiner and the Board stated different grounds for rejection. View "In re Biedermann" on Justia Law

The district court entered summary judgment that Sturm, a manufacturer of cartridges for brewing single servings of coffee, did not infringe Keurig’s patents covering single-serving coffee makers and cartridges for the machines. The court concluded that exhaustion of Keurig’s patent rights was triggered by its sale of a patented item that completely practiced the claimed invention and that its claims were not saved by the fact that a consumer could use non-Keurig cartridges in a Keurig brewer in a noninfringing way. The Federal Circuit affirmed. View "Keurig, Inc. v. Sturm Foods, Inc." on Justia Law

ARRIS and SeaChange provide video-on-demand products and services. ARRIS owns the 804 patent, which discloses a media server capable of transmitting multimedia information over any network configuration in real time to a client that has requested the information, allowing a user to purchase videos that are then streamed to a device such as a television. ARRIS alleged infringement by SeaChange’s Interactive Television. A jury returned a verdict in ARRIS’s favor, finding willful infringement. The Federal Circuit affirmed the verdict and the district court’s decision to enhance the damages award. The district court then permanently enjoined SeaChange from selling products that infringe the 804 patent. SeaChange released a system that it claims is outside the scope of the 804 patent. The district court found that ARRIS failed to prove contempt by clear and convincing evidence. The Federal Circuit affirmed. View "nCUBE Corp. v. Seachange Int'l, Inc." on Justia Law

Intellect’s patents involve wireless transmission of caller identification information and disclose providing caller ID information from a message center to a personal communication device, such as a cell phone, by a wireless network and displaying the caller ID information on the cell phone’s screen. Intellect sued HTC for infringement. After a bench trial, the district court held the asserted patents unenforceable due to inequitable conduct by the inventor, Henderson, who falsely asserted that the invention had been reduced to practice. The Federal Circuit affirmed, holding that Henderson’s explanations were not credible in light of a pattern of deceit. View "Intellect Wireless, Inc. v. HTC Corp." on Justia Law

The patent concerns digital communication systems with data transceivers capable of receiving multiple, analog, high-speed, serial data signals. Once received, the analog data signal must be converted into a digital signal through a process called “sampling” that involves measuring the amplitude of the analog signal at precisely timed intervals to extract the data carried in the analog signal. The receiver needs a way to discern the proper rate at which to sample the analog signal and a means for generating a sampling signal with the appropriate frequency. When data is sent through cables over long distances, the incoming signal frequency can vary. To compensate for variances, receiver circuits adjust the sampling signal to match the frequency and phase of the incoming data signal. The district court held that Emulex infringed the patent. The Federal Circuit affirmed, holding that the patent would not have been obvious at the time of invention and that the district court properly exercised its discretion in granting a permanent injunction with a well-crafted sunset period.View "Broadcom Corp. v. Emulex Corp." on Justia Law