Justia Patents Opinion Summaries

In 2010, Microsoft filed a complaint in the U.S. International Trade Commission, alleging that Motorola had violated the Tariff Act of 1930, 19 U.S.C. 1337, by importing mobile phones and tablets that infringe several Microsoft patents. The Commission instituted an investigation and, after an evidentiary hearing, the ALJ found that the accused Motorola products did not infringe the 054, 762, 376, or 133 patents and that Microsoft had failed to prove that the mobile devices on which it relied actually implemented those patents. The Commission upheld the ALJ’s findings, finding that Microsoft failed to prove that the Microsoft-supported products on which it relied for its domestic-industry showing actually practiced the patents. The Federal Circuit reversed in part, first affirming that Motorola does not infringe the 054 patent and that Microsoft failed to prove that a domestic industry exists for products protected by the 762 and 376 patents. With respect to the 133 patent the Commission relied on incorrect claim constructions in finding no infringement, the only basis for its finding no violation, for the main group of accused products. The court affirmed the noninfringement finding for the accused alternative design. View "Microsoft Corp. v. Int'l Trade Comm'n" on Justia Law

TecSec’s 702, 452, and 781 Patents derive from a common parent application and disclose a system and a method for providing security in a data network by nesting encrypted objects into other objects which are also encrypted, allowing a system to employ different security levels to restrict access to specific compartments of data. The district court found no infringement. The Federal Circuit reversed in part, holding that the court correctly construed the term “multi-level multimedia security,” but incorrectly limited the encrypted data to objects in multimedia form. The court also erred in holding that the term “digital logic means” was a means-plus-function limitation. TecSec may be able to prove infringement against every defendant except PayPal. View "TecSec, Inc. v. Int'l Bus. Mach. Corp." on Justia Law

Rexam, Valois, and MWV compete in the perfume packaging industry. Each sells spray pumps to fragrance houses such as Estee Lauder and Chanel. MWV developed an “invisible” tube that appears to disappear when immersed in liquid, enhancing the aesthetic appearance of the perfume bottle. The inventors needed a transparent material with a refractive index close to that of the perfume liquid. In 2003, Daikin, a plastics supplier, began promoting the fluoropolymer EFEP, a highly transparent fluoropolymer with a refractive index in the correct range. The inventors experimented with EFEP, but the original tubes were hazy and brittle. They tried different production techniques, including a quenching process and eventually developed the NoC® tube. In 2005, they filed patent applications and MWV began marketing the tube. Rexam obtained and analyzed a sample, obtained EFEP, and launched its invisible tube. The district court entered summary judgment of nonobviousness; denied summary judgment of indefiniteness; denied of Rexam’s motion to exclude expert testimony; and found, after trial, infringement of certain MWV patent claims. The Federal Circuit vacated the judgment of nonobviousness, but affirmed the claim constructions, denial of the motion to exclude, and findings of infringement. Rexam and Valois waived their indefiniteness arguments by failing to pursue them at trial. View "MeadWestvaco Corp. v. Rexam Beauty & Closures, Inc." on Justia Law

Sunovion owns the rights to the patent, which is directed to pharmaceutical compositions of the single-enantiomer drug eszopiclone, the active ingredient in the chiral drug marketed as a sleep medication with the brand name Lunesta®. The district court held, on summary judgment, that Dr. Reddy’s Laboratories did not infringe certain claims in that patent. The Federal Circuit reversed. Although the district court did not err in construing the claim term “essentially free” as containing less than 0.25 percent levorotatory isomer, Sunovion was entitled to a judgment of infringement as a matter of law under 35 U.S.C. 271(e)(2)(A). A generic manufacturer’s “certification” pledging not to infringe cannot override the conclusion that when a drug manufacturer seeks FDA approval to market a generic compound within the scope of a valid patent, it is an infringement as a matter of law. View "Sunovion Pharm., Inc. v. Teva Pharm. USA, Inc." on Justia Law

The patent, entitled “Intermediate Network Authentication,” concerns internet security, and was developed by a scientist at the Naval Research Laboratory (NRL). The NRL allowed the patent to lapse for nonpayment of the 7.5-year maintenance fee. Two weeks after the lapse, NRL received an inquiry from Network Signatures about licensing the patent and successfully petitioned the Patent and Trademark Office (PTO) to accept delayed payment of the fee. Network Signatures sued State Farm for infringement of the patent. In defense, State Farm asserted that the patent was permanently unenforceable on the ground that the NRL patent attorney had engaged in inequitable conduct by “falsely representing” to the PTO that the NRL’s non-payment of the maintenance fee was “unintentional.” The district court granted summary judgment of inequitable conduct, and found the patent unenforceable. The Federal Circuit reversed, holding that the PTO Director acted in accordance with law and within his discretion in excusing the delayed payment, and that inequitable conduct was not established. View "Network Signatures, Inc. v. State Farm Mut. Auto. Ins., Inc." on Justia Law

Conventional memory circuits asynchronously transfer all of the data upon request, which can tie up the computer system for long periods of time and create a “bottleneck” that slows down computer operations. The patent at issue solves the problem using a synchronous memory system to transfer data. The Board of Patent Appeals and Interferences held that certain claims of the patent were invalid for anticipation and obviousness. The Federal Circuit held that the Board correctly construed claims: that the “external clock signal” only requires the clock to be periodic during the data input phases, as opposed to being periodic for all system operations and that “write request” could include “the state of a signal,” which is usually represented by a single bit. The court vacated with respect to the obviousness determination. View "Rambus Inc. v. Rea" on Justia Law

BDI is the owner a design patent and the manufacturer of slippers known as SNOOZIES®. High Point manufactures and distributes the accused FUZZY BABBA® slippers, which are sold through various retailers, including Meijer, Sears, and WalMart. BDI sent High Point a cease and desist letter, asserting patent infringement. High Point sought a declaratory judgment. The district court held BDI’s asserted design patent invalid on summary judgment and dismissed BDI’s trade dress claims with prejudice. The Federal Circuit reversed. The district court applied the incorrect standard; a reasonable jury could, under the correct standard, find the patent not invalid based on functionality. On remand, the district court should weigh High Point’s notice of BDI’s trade dress claim and initial belief that its original complaint encompassed such a claim and the absence of apparent prejudice to High Point against the fact that BDI had always been in possession of the information added in the proposed amendments and could have asked to clarify its pleading sooner. View "High Point Design LLC v. Buyer's Direct, Inc." on Justia Law

The patents at issue relate to methods and devices for sealing a vascular puncture, which occurs when a medical procedure requires a puncture through the skin and into a vein or artery to insert a medical device, such as a catheter, into a patient’s vasculature. After such a procedure, the medical professional typically removes the medical device from the vasculature. Prior to development of the technology at issue, the medical professional was then required to apply external pressure to the puncture site until clotting occurred, sometimes for an extended period of time. This caused discomfort and increased the recovery time. The Janzen and Fowler patents disclose methods and devices for sealing a vascular puncture to improve patient recovery. The district court held that the safe-harbor provision of 35 U.S.C. 121 protects the Janzen patent from invalidity due to double-patenting; construed key terms in the Janzen patent; and found that the Fowler patents were not invalid for obviousness. The Federal Circuit reversed the safe harbor ruling, which rendered the rulings regarding the claim constructions moot, and affirmed that the Fowler patents are nonobvious and not shown to be invalid. View "St. Jude Med., Inc. v. Access Closure, Inc." on Justia Law

In 1997 Wawrzynski was awarded the 990 patent, entitled “Method of Food Article Dipping and Wiping in a Condiment Container.” The description illustrates a condiment container that has a flexible cap with a slitted opening. A user introduces a food article, such as a French fry, into the container through the slit and dips it into the condiment. As the food article is removed, the flexible cap wipes away excess condiment , reducing the likelihood of a drip or spill. . Wawrzynski presented his “Little Dipper” concept, permitting a consumer to either dip or squeeze, to Heinz in a 2008. Heinz indicated that the company was not interested in the product, but months later, released its new “Dip & Squeeze®” packet. Wawrzynski filed a lawsuit asserting breach of an implied contract and unjust enrichment. Heinz counterclaimed that Heinz did not infringe the patent and that the patent was invalid. The district court entered summary judgment, holding that federal patent law preempted the state law claims and that Wawrzynski failed to prove infringement. The Federal Circuit transferred to the Third Circuit, stating that its subject matter jurisdiction over patent disputes derives solely from the complaint, not from any counterclaim. View "Wawrzynski v. H.J. Heinz Co." on Justia Law

Accenture alleged infringement of its patent, which describes a “computer program ... for handling insurance-related tasks” and discloses software components of the program, including a “data component that stores, retrieves and manipulates data” and a client component that “transmits and receives data to/from the data component.” The client component includes a business component that “serves as a data cache and includes logic for manipulating the data.” The program also describes a controller component to handle program events and an adapter component to interface with a data repository. The district court found all of the claims invalid under 35 U.S.C. 101. Accenture appealed only with respect to claims 1–7, directed to a system for generating tasks to be performed in an insurance organization, but did not appeal the similar method claims 8–22. The Federal Circuit affirmed, holding that the system claims at issue recite patent-ineligible subject matter both because Accenture was unable to point to any substantial limitations that separate them from the similar, patent-ineligible method claim and because the system claim does not, on its own, provide substantial limitations to the claim’s patent-ineligible abstract idea. View "Accenture Global Servs. GMBH v. Guidewire Software, Inc." on Justia Law