Justia Patents Opinion Summaries

Taurus sued DaimlerChrysler, alleging that external websites infringed its patent for “a computer system for managing product knowledge related to products offered for sale by a selling entity.” Daimler Chrysler asserted license and release defenses, asserted a breach of contract counterclaim, and filed a contract claim against third-party defendants (including Orion), which, it claimed violated a 2006 patent licensing agreement between DaimlerChrysler and Orion, to settle prior patent infringement suits. The district court entered summary judgment, finding that the accused websites did not infringe any asserted claims and that certain claims were invalid as anticipated by prior art. The district court found the DaimlerChrysler suit to be exceptional under 35 U.S.C. 285, and awarded damages of $1,644,906.12, for costs incurred in Chrysler’s defense. With respect to remaining issues, the district court: found that certain third parties were alter egos and declined to dismiss for lack of jurisdiction; held that the 2006 agreement did not provide a release to the infringement alleged in the patent suit; held that issues of fact remained as to whether certain third parties had breached a warranty in the 2006 agreement; held that Orion had breached the warranty; and imposed sanctions on Orion and another for pre-trial witness tampering (those parties were not permitted to present evidence to support their defense that Chrysler did not rely on the warranty). The Federal Circuit affirmed, except with respect to attorney fees. View "Taurus IP, LLC v. DaimlerChrysler Corp." on Justia Law

Apple’s patents disclose a smartphone touch panel with a transparent capacitive sensing medium that can detect multiple touches at once by employing a matrix of electrodes connected to circuits that measure the change in charge that occurs when pressure is applied to the screen. The pressure-induced change occurs because electrode rows are in a different layer than electrode columns. When a user touches the screen, the pressure applied at each intersection point causes charge to flow between the electrodes at that node. Measuring circuits connected to the electrodes scan the matrix and measure the displaced charge at each node. By detecting these changes, the panel can determine if and where a user has touched the screen. The patent also discloses how to make the touchscreen transparent. The International Trade Commission found asserted claims of one patent invalid and that Motorola did not infringe asserted claims of the other. The Federal Circuit vacated the ITC decision that Motorola does not infringe and remanded to allow the ITC to consider whether the accused products infringe under the correct construction of “mathematically fitting an ellipse.” The court also vacated a finding of obviousness as to one claim, but affirmed a finding that a claim was not anticipated. View "Apple Inc. v. Int'l Trade Comm'n" on Justia Law

Rembrandt’s patent relates to contact lenses that have a highly wettable surface and are permeable to oxygen. The patent discloses a soft gas permeable lens with an acrylic layer on the surface of the lens body that increases the wettability and comfort of the contact lens. The district court held that Johnson & Johnson did not infringe the patent. The Federal Circuit affirmed. View "Rembrandt Vision Techs., L.P. v. Johnson & Johnson Vision Care, Inc." on Justia Law

3M sells laminate products such as diapers and claimed infringement of four patents by Tredegar, a supplier of breathable and nonwoven film laminates for personal care products, including baby diapers, training pants, and adult incontinence products. After the district court construed claim terms the parties stipulated to noninfringement. The Federal Circuit remanded. The court affirmed the appropriate scope of the claim terms “continuous contact” and “continuous microtextured skin layer over substantially the entire laminate,” but clarified the appropriate scope of those terms. The court reversed claim constructions relating to the terms grouped as “preferential activation zone” and the term “ribbon,” finding that the district court erroneously limited certain claim terms in a manner inconsistent with the intrinsic disclosures. View "3M Innovative Props. Co. v. Tredegar Corp." on Justia Law

Tetra Pak’s patent involves commercial cheese-making vats. The district court granted summary judgment, holding that CSI infringed under the doctrine of equivalents and had not proven the patent invalid, and entered a permanent injunction against CSI. The Federal Circuit affirmed. View "Cheese Sys., Inc. v. Tetra Pak Cheese & Powder Sys., Inc." on Justia Law

The Plantronics patent is directed to a concha-style headset for transmitting received sounds to the ear of a user, and discloses an apparatus for stabilizing a concha style headset during use. The district court granted-in-part Aliph’s motion for summary judgment of noninfringement and invalidity, construing certain terms and holding the asserted claims invalid as obvious. The Federal Circuit reversed in part, vacated in part, and remanded, holding that the terms “stabilizer support member” and the “concha stabilizer” are not structurally limited either in claim language or in their corresponding description in the specification. The district court concluded that the patent was invalid as obvious before considering objective indications of nonobviousness. View "Plantronics, Inc. v. Aliph, Inc." on Justia Law

CMW’s patent generally relates to a two-pipe drill for boring underground holes horizontally. An inner pipe rotates the drill bit. An outer pipe, with a body and casing, is used for steering. The patent discusses a structure called a “deflection shoe” as a steering mechanism; it is included on one side of the casing to create an asymmetry about the casing’s centerline axis. If the casing does not rotate, the deflection shoe causes the drill to deflect away from a straight path. When the casing rotates, the drill follows a straight horizontal path. CMW sued Vermeer for infringement. The district court held that the accused commercial products and non-commercial prototypes do not infringe, literally or under the doctrine of equivalents. The Federal Circuit vacated in part, holding that CMW did not have sufficient notice that the prototypes were within the scope of the summary judgment decision. The court reversed with respect to the doctrine of equivalents, but affirmed that there is no literal infringement. View "Charles Mach. Works, Inc. v. Vermeer Mfg. Co." on Justia Law

Generic manufacturers submitted Abbreviated New Drug Applications (ANDAs) seeking FDA approval to market generic versions of Copaxone®, a drug used in treating multiple sclerosis. Teva, which markets Copaxone®, sued the generic manufacturers for patent infringement under 35 U.S.C. 271(e)(2)(A). The patents at issue share a common specification and are listed in the Approved Drug Products with Therapeutic Equivalence Evaluations (Orange Book) entry for Copaxone®. The patents include claims reciting a product called copolymer-1 and recite two methods of making copolymer-1: one using statistical average measures and the other describing how many molecules in a polymer sample have molecular weights that fall within an arbitrarily set range. The district court found that various claims of the nine patents by Teva are infringed, based on holdings regarding indefiniteness, nonenablement, and obviousness. The Federal Circuit affirmed in part and reversed in part, holding that Group I claims are invalid for indefiniteness, but that Group II claims were not proven indefinite. The district court did not err in finding that the claims are infringed, and that the generic manufacturers failed to prove that the claims would have been obvious and are not enabled. View "Teva Pharm. USA, Inc. v. Sandoz, Inc." on Justia Law

The patent at issue concerns methods for preventing bovine mastitis, the inflammation of udder tissue in cows, and is entitled “Antiinfective free intramammary veterinary composition.” The summary of the invention describes how the composition employs a physical barrier within the teat canal to block introduction of mastitis-causing organisms without requiring use of antiinfectives such as antibiotics. A patent examiner rejected certain claims introduced in the context of ex parte reexamination. The Patent Trial and Appeal Board and Federal Circuit affirmed, finding that substantial evidence supported the Board’s finding that one claim failed the written description requirement because the disclosure did not “describe[] a formulation excluding a specific species of the anti-infective genus, while permitting others to be present.” View "In re: Bimeda Research & Dev. Ltd." on Justia Law

Novozymes’s 723 patent, entitled “Alpha-Amylase Mutants with Altered Properties,” relates to recombinant enzyme technology. Enzymes are proteins that catalyze biochemical reactions; they facilitate molecular processes that would not occur or would occur more slowly in their absence. The 723 patent claims particular modified enzymes with improved function and stability under certain conditions. Novozymes sued DuPont, alleging infringement. DuPont counterclaimed, seeking a declaratory judgment of invalidity for failing to satisfy enablement and written description requirements of 35 U.S.C. 112. The district court granted Novozymes summary judgment on the issue of infringement and denied DuPont summary judgment of invalidity. A jury concluded that the claims were not invalid and awarded infringement damages of more than $18 million, but the district court granted DuPont’s post-trial motion for judgment as a matter of law that the claims are invalid for failure to satisfy the written description requirement. The Federal Circuit affirmed. To actually possess the variant enzymes claimed in the patent would require Novozymes to confirm its predictions by actually making and testing individual variants or at least identifying subclasses of variants that could be expected to possess the claimed properties, which it did not do before filing its 2000 application. View "Novozymes A/S v. DuPont Nutrition Biosciences, APS" on Justia Law