Justia Patents Opinion SummariesArticles Posted in US Court of Appeals for the Eighth Circuit
Sleep Number Corporation v. Steven Young
Sleep Number partnered with Defendants and through their partnership, Defendants’ inventions were adapted to create SleepIQ technology. After two years as employees, Defendants informed Sleep Number that they wished to pursue their own venture. The parties entered into a consulting agreement requiring Defendants to disclose and assign to Sleep Number the rights to inventions within a defined Product Development Scope (“PDS”).Sleep Number sued Defendants., asserting ownership of the inventions claimed in certain patent applications filed by UDP with the United States Patent and Trademark Office (“USPTO”). The district court granted Sleep Number’s motion for a preliminary injunction preventing the defendants from further prosecuting or amending the patent applications. The Eighth Circuit affirmed the district court’s grant of Plaintiff’s motion for a preliminary injunction. The court held that the district court did not err in determining that Sleep Number had a fair chance of success on the merits of its claims; nor did the court err in concluding that Sleep Number has demonstrated a threat of irreparable harm in the absence of an injunction; further the remaining factors of the balance of the harms and public interest both weighed in favor of Sleep Number. The court reasoned that the plain meaning of the language in the consulting agreements clearly and unambiguously places the inventions described in the patent applications within the PDS. Finally, absent an injunction, Sleep Number faces a threat of harm if it cannot participate in the patent-prosecution process for the patent applications. View "Sleep Number Corporation v. Steven Young" on Justia Law
Tumey v. Mycroft AI, Inc.
Tumey filed suit alleging that Tumey's representation of Voice Tech Corporation in pending and separate patent infringement lawsuits against Mycroft prompted Mycroft to retaliate by launching and/or inspiring a series of cyber-attacks against Tumey. The complaint alleges violations of the Racketeer Influenced and Corrupt Organization Act, the Computer Fraud and Abuse Act, the Stored Wire and Electronic Communications Act, and various state and common law claims.The Eighth Circuit applied the Dataphase factors and vacated the district court's grant of preliminary injunctive relief to Tumey, concluding that Tumey did not show a likelihood of success on the merits of its claims. In this case, even if there was no procedural due process issue, the district court committed a clear error of judgment when it issued a preliminary injunction based on a lack of evidence demonstrating Mycroft was responsible for the conduct at issue. Furthermore, even if Tumey came forward with sufficient evidence to connect Mycroft to the unlawful acts, Tumey has not convinced the court that money damages are insufficient to compensate him for the alleged injuries. The court found that this is a rare case in which the history, proceedings, and order reflect a sufficiently high degree of antagonism against Mycroft to warrant reassignment of the case on remand. View "Tumey v. Mycroft AI, Inc." on Justia Law