Justia Patents Opinion Summaries

In 2006, a footwear company sued several competitors for patent infringement. One of the competitors, Dawgs, counterclaimed in 2016, alleging that the plaintiff falsely advertised its product material, Croslite, as "patented," "proprietary," and "exclusive," misleading consumers about the nature and quality of its products. Dawgs argued that these false claims caused consumers to believe that Croslite was superior to other materials used in competitors' products.The United States District Court for the District of Colorado granted summary judgment in favor of the plaintiff, Crocs, concluding that Dawgs' counterclaim failed as a matter of law. The district court determined that the false advertising claims were akin to claims of inventorship, which are not actionable under Section 43(a) of the Lanham Act, based on precedents set by the Supreme Court in Dastar Corp. v. Twentieth Century Fox Film Corp. and the Federal Circuit in Baden Sports, Inc. v. Molten USA, Inc.The United States Court of Appeals for the Federal Circuit reviewed the case and reversed the district court's decision. The appellate court held that a cause of action under Section 43(a)(1)(B) of the Lanham Act arises when a party falsely claims that it possesses a patent on a product feature and advertises that feature in a way that misleads consumers about the nature, characteristics, or qualities of the product. The court found that Dawgs had sufficiently alleged that Crocs' false claims about Croslite being patented misled consumers about the material's qualities, thus stating a valid cause of action under the Lanham Act. The case was remanded for further proceedings. View "CROCS, INC. v. EFFERVESCENT, INC. " on Justia Law

Provisur Technologies, Inc. owns patents related to food-processing machinery, specifically high-speed mechanical slicers and a fill and packaging apparatus. Provisur sued Weber, Inc. and its affiliates, alleging that Weber's food slicers and SmartLoader products infringed on these patents. The case was tried before a jury, which found that Weber willfully infringed several claims of Provisur's patents and awarded Provisur approximately $10.5 million in damages.The United States District Court for the Western District of Missouri denied Weber's motions for judgment as a matter of law (JMOL) on noninfringement and willfulness, as well as a motion for a new trial on infringement, willfulness, and damages. Weber appealed these decisions.The United States Court of Appeals for the Federal Circuit reviewed the case. The court affirmed the district court's denial of JMOL for noninfringement regarding the '812 and '436 patents, as Weber conceded its noninfringement arguments were no longer available due to an intervening decision. However, the court reversed the district court's denial of JMOL for noninfringement of the '936 patent, finding that Provisur failed to provide sufficient evidence that Weber's SmartLoader could be readily configured to infringe the patent.The court also reversed the district court's denial of JMOL on willfulness, ruling that the evidence presented, including testimony about Weber's failure to consult a third party, was insufficient to establish willful infringement. Additionally, the court found that the district court abused its discretion in allowing Provisur to use the entire market value rule for calculating damages without sufficient evidence that the patented features drove customer demand for the entire slicing line. Consequently, the court reversed the denial of a new trial on damages.The case was remanded for further proceedings consistent with the Federal Circuit's decision. View "PROVISUR TECHNOLOGIES, INC. v. WEBER, INC. " on Justia Law

Astellas Pharma, Inc. and its affiliates (collectively, "Astellas") sued Sandoz Inc. and other defendants for patent infringement related to their attempts to market generic versions of Myrbetriq®, a drug used to treat overactive bladder. The patent in question, U.S. Patent 10,842,780, covers sustained-release formulations of mirabegron, which Astellas developed to mitigate the drug's undesirable "food effect."The United States District Court for the District of Delaware held a five-day bench trial focusing on issues of infringement and validity under 35 U.S.C. § 112. However, the district court, sua sponte, determined that claims 5, 20, and 25 of the '780 patent were invalid under 35 U.S.C. § 101, reasoning that the claims were directed to an ineligible natural law. This decision was made despite the fact that Sandoz had not raised a § 101 defense during the trial or in its post-trial briefing.The United States Court of Appeals for the Federal Circuit reviewed the case and found that the district court had abused its discretion by addressing a ground not raised by the parties, thereby disregarding the principle of party presentation. The Federal Circuit vacated the district court's judgment and remanded the case for adjudication of the issues properly raised by the parties, specifically infringement and validity under 35 U.S.C. § 112. The Federal Circuit also declined Astellas's request to reassign the case to a different judge, trusting that the district court could resolve the remaining issues impartially. View "ASTELLAS PHARMA, INC. v. SANDOZ INC. " on Justia Law

The case involves Vascular Solutions LLC, Teleflex LLC, Arrow International LLC, and Teleflex Life Sciences LLC (collectively, Teleflex) suing Medtronic, Inc. and Medtronic Vascular, Inc. (collectively, Medtronic) for patent infringement. Teleflex asserted forty claims across seven patents related to a coaxial guide catheter. The District Court for the District of Minnesota conducted claim construction proceedings and found the term "substantially rigid portion/segment" to be indefinite, invalidating all asserted claims. The parties stipulated to final judgment based on this determination, leading Teleflex to appeal.Previously, in the District Court for the District of Minnesota, Teleflex sought a preliminary injunction, which was denied due to substantial questions of invalidity. The court stayed the case pending inter partes review (IPR) proceedings. The Patent Trial and Appeal Board (PTAB) found some claims unpatentable but upheld others. Teleflex then filed a second preliminary injunction request, which was also denied. The district court appointed an independent expert, Andrei Iancu, who proposed a construction for "substantially rigid portion/segment." The district court ultimately found the term indefinite and invalidated all claims.The United States Court of Appeals for the Federal Circuit reviewed the case. The court held that the district court erred in determining the claims were mutually exclusive and indefinite. The Federal Circuit clarified that the boundary of the "substantially rigid portion/segment" does not need to be consistent across claims and can be understood functionally. The court vacated the district court's final judgment and remanded the case for further proceedings, instructing that the claims are not necessarily mutually exclusive and that the term "substantially rigid portion/segment" does not need a consistent boundary across different independent claims. View "Vascular Solutions LLC v. Medtronic, Inc." on Justia Law

Contour IP Holding LLC sued GoPro, Inc. for patent infringement, alleging that GoPro's point-of-view digital video cameras infringed on Contour's patents, specifically U.S. Patent Nos. 8,890,954 and 8,896,694. These patents relate to portable, point-of-view video cameras designed for hands-free use, with features allowing remote image acquisition control and viewing. The patents describe a system where the camera generates high and low-quality video streams in parallel, with the low-quality stream being wirelessly transmitted to a remote device for real-time viewing and adjustment.The United States District Court for the Northern District of California initially construed the term "generate" in the patents to mean "record in parallel from the video image data." Later, GoPro moved for summary judgment, arguing that the claims were patent ineligible under 35 U.S.C. § 101. The district court agreed, finding that the claims were directed to the abstract idea of creating and transmitting video at different resolutions and adjusting the video’s settings remotely. The court concluded that the claims did not include an inventive concept sufficient to transform the abstract idea into a patent-eligible application and entered judgment against Contour.The United States Court of Appeals for the Federal Circuit reviewed the case and reversed the district court's decision. The Federal Circuit held that the claims were not directed to an abstract idea but to a specific technological improvement in POV camera technology. The court found that the claims described a specific means of generating high and low-quality video streams in parallel and wirelessly transmitting the low-quality stream to a remote device, which provided a technological solution to a technological problem. Therefore, the claims were patent eligible under 35 U.S.C. § 101. The case was remanded for further proceedings. View "CONTOUR IP HOLDING LLC v. GOPRO, INC. " on Justia Law

ParkerVision, Inc. sued Qualcomm Inc. in 2014, alleging infringement of patents related to wireless communications technology. This followed a 2011 lawsuit where ParkerVision claimed Qualcomm infringed on different but related patents. In the 2011 case, the court granted judgment as a matter of law (JMOL) of non-infringement, which was affirmed on appeal. In the 2014 case, the district court granted Qualcomm’s motion for summary judgment of non-infringement based on collateral estoppel from the 2011 case and excluded certain expert testimonies from ParkerVision.The district court for the Middle District of Florida granted Qualcomm’s motions, concluding that the claims in the 2014 case were materially similar to those in the 2011 case, thus applying collateral estoppel. The court also excluded ParkerVision’s expert testimonies on validity and infringement, deeming them unreliable due to a lack of testing and simulation.The United States Court of Appeals for the Federal Circuit reviewed the case. It vacated the summary judgment of non-infringement, finding that the district court erred by not conducting a proper claim construction to determine if the claims in the 2014 case were materially different from those in the 2011 case. The appellate court also reversed the exclusion of ParkerVision’s expert testimonies, ruling that the district court improperly required testing and simulation for the expert opinions to be considered reliable. The case was remanded for further proceedings to determine the proper scope of the claims and whether the differences in the claims would materially alter the question of infringement. View "PARKERVISION, INC. v. QUALCOMM INCORPORATED " on Justia Law

Osseo Imaging, LLC sued Planmeca USA Inc. for patent infringement, alleging that Planmeca's ProMax 3D imaging systems infringed on Osseo's U.S. Patent Nos. 6,381,301, 6,944,262, and 8,498,374. These patents relate to orthopedic imaging systems that use X-ray beam techniques to create tomographic and/or densitometric models. The jury found that Planmeca infringed the asserted claims and that the claims were not invalid for obviousness.The United States District Court for the District of Delaware denied Planmeca's motion for judgment as a matter of law (JMOL) on both noninfringement and invalidity. Planmeca argued that Osseo's expert, Dr. Omid Kia, was not qualified to testify because he did not have the requisite experience at the time of the patents' invention. The district court rejected this argument, stating that there is no legal requirement for an expert to have acquired their expertise before the patent's effective date. The court also found that substantial evidence supported the jury's verdict.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Dr. Kia's testimony was admissible and that there is no requirement for an expert to have the requisite skill at the time of the invention. The court found that substantial evidence supported the jury's findings of infringement and nonobviousness. Specifically, the court noted that the evidence showed Planmeca's systems calculated Hounsfield Unit values representing bone density, merged information from multiple tomographic scans, and facilitated the comparison of densitometry models. The court also upheld the jury's finding that it would not have been obvious to combine the prior art references cited by Planmeca. Thus, the Federal Circuit affirmed the district court's denial of JMOL on all issues. View "OSSEO IMAGING, LLC v. PLANMECA USA INC. " on Justia Law

Broadband iTV sued Amazon in the Western District of Texas, alleging patent infringement of five patents related to electronic programming guides for televisions. Amazon moved for summary judgment, arguing that the claims were patent-ineligible under 35 U.S.C. § 101. The district court granted Amazon’s motion, finding the claims were directed to an abstract idea and lacked an inventive step to transform the abstract idea into a patent-eligible invention. Broadband iTV appealed.The United States District Court for the Western District of Texas found that the claims of the ’026 patent family were directed to the abstract idea of receiving hierarchical information and organizing the display of video content. The court also found that the claims of the ’825 patent were directed to the abstract idea of collecting and using a viewer’s video history to suggest categories of video content. The court concluded that neither set of claims included elements that transformed the abstract ideas into patent-eligible inventions, as they recited only generic and conventional components.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the district court’s decision. The Federal Circuit agreed that the claims of the ’026 patent family were directed to an abstract idea and did not include an inventive concept that transformed the claims into something more than the abstract idea itself. Similarly, the court found that the claims of the ’825 patent were directed to an abstract idea and lacked an inventive concept. The court held that the asserted claims were patent-ineligible under § 101 and affirmed the district court’s grant of summary judgment in favor of Amazon. View "BROADBAND ITV, INC. v. AMAZON.COM, INC. " on Justia Law

The case involves the Wisconsin Alumni Research Foundation (WARF) and Apple Inc. WARF accused Apple of infringing U.S. Patent No. 5,781,752 (the '752 patent) with its A7 and A8 processors in a lawsuit filed in 2014 (WARF I). WARF later filed a second lawsuit (WARF II) accusing Apple's A9 and A10 processors of infringing the same patent. In WARF I, the jury found that Apple’s A7 and A8 processors literally infringed the '752 patent. However, Apple appealed, and the United States Court of Appeals for the Federal Circuit reversed the jury's verdict, finding that no reasonable jury could find literal infringement under the plain and ordinary meaning of the term "particular" as used in the patent claims.In the district court for WARF I, WARF had abandoned its doctrine-of-equivalents theory in exchange for Apple not presenting certain evidence at trial. After the Federal Circuit's reversal, WARF sought to reassert the doctrine-of-equivalents theory, but the district court denied this request, citing WARF's prior abandonment and the preclusive effect of the Federal Circuit's interpretation of "particular."In WARF II, the district court stayed proceedings pending the outcome of the appeal in WARF I. After the Federal Circuit's decision, WARF attempted to continue WARF II under the doctrine of equivalents. The district court found that WARF I precluded WARF from proceeding in WARF II, citing issue preclusion and the Kessler doctrine, which prevents repeated litigation of the same issue against the same party.The United States Court of Appeals for the Federal Circuit affirmed the district court's decisions in both WARF I and WARF II. The court held that WARF had waived its doctrine-of-equivalents theory in WARF I and that issue preclusion and the Kessler doctrine barred WARF II. The court concluded that the A7/A8 and A9/A10 processors were essentially the same for the purposes of preclusion and that literal infringement and the doctrine of equivalents are part of the same overall issue of infringement. View "WISCONSIN ALUMNI RESEARCH FOUNDATION v. APPLE INC. " on Justia Law

The plaintiff, Realtime Adaptive Streaming LLC, sued DISH and related Sling entities for alleged infringement of three patents related to digital data compression. The district court found the asserted claims of one patent ineligible as abstract under 35 U.S.C. § 101. Defendants filed motions to dismiss and for judgment on the pleadings, which the district court denied, opting to rehear invalidity arguments after claim construction. The district court later stayed the case pending inter partes review (IPR) proceedings, which resulted in some claims being found unpatentable. The stay was lifted after the IPR proceedings concluded, and the district court eventually granted summary judgment of invalidity for the remaining patent claims.The United States District Court for the District of Colorado awarded attorneys’ fees to the defendants, citing six "red flags" that should have warned Realtime that its case was flawed. These included prior court decisions finding similar claims ineligible, Board decisions invalidating related patent claims, non-final office actions rejecting claims in the reexamination of the patent at issue, a notice letter from DISH warning of potential fees, and expert opinions from DISH’s witness. The district court found that the totality of these circumstances rendered the case exceptional.The United States Court of Appeals for the Federal Circuit reviewed the district court’s decision and vacated the award of attorneys’ fees. The appellate court found that some of the red flags cited by the district court should not have been given weight, such as the Adaptive Streaming decision and the Board’s decisions on different patents. The court also noted that the district court failed to adequately explain how certain factors, like the notice letter and expert opinions, constituted red flags. The case was remanded for the district court to reconsider the attorneys’ fees award in light of the appellate court’s findings. View "REALTIME ADAPTIVE STREAMING LLC v. SLING TV, L.L.C. " on Justia Law