Justia Patents Opinion Summaries

Nordock and Systems are rivals in the loading dock device industry.Both design, manufacture, and sell dock levelers--mechanical devices used to create a bridge between loading dock surfaces and the surfaces of truckload beds.” Nordock sued, alleging infringement of Design Patent 754, which claims the ornamental design of a lip and hinge plate for a dock leveler. A jury found that Systems’ hydraulic dock levelers infringe, and that the patent is not invalid. The district court awarded Nordock $46,825 in damages as a reasonable royalty. The Federal Circuit vacated the award and remanded, finding that the district court erred in its assessment of design patent damages under 35 U.S.C. 289, but otherwise affirmed. View "Nordock, Inc. v. Systems, Inc." on Justia Law

The state filed a complaint, alleging that letters mailed by MPHJ to Vermont businesses informing them that they may be infringing certain patents were deceptive and violated the Vermont Consumer Protection Act, 9 V.S.A. 2451. MPHJ is a non-practicing entity incorporated in Delaware that acts through shell corporations incorporated in many states. MPHJ removed the case twice to federal court, once under the original complaint and once under an amended complaint. The district court remanded the case to state court both times. The Federal Circuit affirmed. While 28 U.S.C. 1442(a)(2), provides jurisdiction “in any civil action arising under, or in any civil action in which a party has asserted a compulsory counterclaim arising under, any Act of Congress relating to patents,” the patents at issue were transferred to MPHJ from the original patent owner; they were not directly “derived from a federal officer.” The complaint neither alleged violation of nor sought relief under the Vermont Bad Faith Assertions of Patent Infringement Act so there is no risk that the state court action can affect the validity of federal law. View "Vermont v. MPHJ Tech. Inv., LLC" on Justia Law

Shire’s patents are directed to derivatives of amphetamines, used to treat various disorders, including attention deficit hyperactivity disorder. A drawback to the use of amphetamines is their potential for abuse. The patents describe modifying amphetamine to decrease its activity when administered in high doses—as when the drug is being abused—but to maintain activity similar to that of unmodified amphetamine when delivered at lower doses. Shire’s FDA-approved capsules are distributed under the brand name Vyvanse®. The FDA’s Approved Drug Products with Therapeutic Equivalence Evaluations (Orange Book) lists all the Vyvanse® patents. Defendants filed Abbreviated New Drug Applications (ANDAs) for generic versions of Vyvanse® before expiration of the patents The ANDAs included Paragraph IV certifications, 21 U.S.C. 355(j)(2)(A)(vii)(IV), stating that the patent claims are invalid or not infringed. Shire sued under 35 U.S.C. 271(e). The court found certain claims not invalid, denied defendants’ motion to amend their invalidity contentions to include an on-sale bar claim, and found that Johnson induced infringement by providing the active pharmaceutical ingredient to the ANDA defendants. The Federal Circuit affirmed in part, finding that defendants failed to raise a genuine issue of material fact that the asserted claims are obvious and that court did not abuse its discretion in denying the motion to amend. In the circumstances of this case Johnson cannot be liable for induced infringement before FDA approval of the ANDA application. View "Shire LLC v. Amneal Pharma., LLC" on Justia Law

Summit owns the 482 patent, entitled “Web-based Media Submission Tool,” relating to the processing of digital content, such as digital photos. The invention “provides an improved web-based media submission tool” that includes “several unique and valuable functions.” The embodiment focuses on a tool used to submit photos to a website; it is described as software that allows a user to place the photo into a website form either by dragging and dropping the photo from the user’s computer or by using a mouse click within the website. The “intelligent preprocessing” taught by the patent includes the “ability to control the width and height of the media object identifier and the ability to preprocess the media objects in any number of ways prior to transporting to a second location.” A jury found the patent not invalid and infringed and awarded $15 million in damages. The Federal Circuit affirmed the district court’s claim construction of “being provided to;” the infringement and invalidity verdicts; the district court’s determination regarding the admissibility of Summit’s damages expert’s testimony; the court’s determination regarding the damages award; and the determination that Summit is not entitled to a running royalty. View "Summit 6, LLC v. Samsung Elecs. Co., Ltd." on Justia Law

SCA owns the 646 patent, relating to adult incontinence products. In 2003 SCA wrote to First Quality, stating that First’s products might infringe the patent. First responded that the patent was invalidated by an earlier patent. SCA then filed an ex parte reexamination request. In 2007, the PTO confirmed the patentability of the original claims and issued new claims. SCA never notified First Quality about the reexamination, believing that it had no obligation to do so because the PTO provides public notice of all reexaminations. First no longer considered the 646 patent “an issue” and, in 2006, expanded its line of incontinence products at a cost of $10 million. SCA did not contact First until 2010, when it filed an infringement suit. SCA claims it spent three years implementing new business structures, evaluating outside counsel, and examining potentially infringing products. The district court dismissed, finding SCA’s claims barred by laches and equitable estoppel. On rehearing, en banc, in light of the Supreme Court’s 2014 decision, Petrella v. MetroGoldwyn-Mayer, the Federal Circuit reversed. Laches remains a defense to legal relief in a patent infringement suit after Petrella; courts must weigh the facts underlying laches when considering an injunction. However, absent extraordinary circumstances, laches does not preclude an ongoing royalty. View "SCA Hygiene Prods. v. First Quality Baby Prods., LLC" on Justia Law

Apple has multiple patents for features of the iPhone and, in 2012, sued Samsung, alleging infringement of five patents directed to smartphone and tablet interfaces. The district court held on summary judgment that Samsung infringed the 172 patent. A jury found that nine Samsung products infringed one or both of Apple’s 647 and 721 patents and awarded a total of $119,625,000. Apple sought a permanent injunction to bar Samsung from making, using, selling, developing, advertising, or importing software or code capable of implementing the infringing features in its products, with a 30-day “sunset period” that would stay enforcement of the injunction until 30 days after it was entered , during which Samsung could design around the infringing features. The district court denied Apple’s motion. The Federal Circuit vacated, Although the evidence may not make a strong case of irreparable harm, Apple satisfied the causal nexus requirement and therefore established irreparable harm. Apple also established that the harm it will suffer is not easily compensable at law. As the district court found, the balance of hardships and public interest weigh strongly in favor of an injunction. View "Apple, Inc.. v. Samsung Elecs. Co., Ltd." on Justia Law

Astornet alleges that it is sole exclusive licensee and owner of all rights in the 844 patent, issued in 2009 to Haddad as the inventor and entitled “Airport vehicular gate entry access system” and asserted the patent against NCR, MorphoTrust USA, and BAE Astornet alleged that the three had contracts with the Transportation Security Administration (TSA) to supply boarding-pass scanning systems; that TSA’s use of the equipment infringed and would infringe the patent; and that NCR and MorphoTrust were bidding for another contract to supply modified equipment whose use by TSA would also infringe. The Federal Circuit affirmed dismissal, finding that Astornet’s exclusive remedy for the alleged infringement was a suit against the government in the Court of Federal Claims under 28 U.S.C. 1498. View "Astornet Techs., Inc. v. BAE Sys., Inc." on Justia Law

R+L claimed infringement of the 078 patent, which generally relates to an improved method of consolidating freight into trailers to optimize delivery efficiencies for the loads in each trailer. While the case was pending, R+L filed for ex parte reexamination of the patent. Although the patent survived, R+L added language to all of the claims at issue. Because the district court determined that the new claims were not substantially identical to the initial claims of the 078 patent, and because there was no dispute that Qualcomm ceased its allegedly infringing activity before the reexamination certificate issued, R+L stipulated to final judgment, dismissing its infringement claim against Qualcomm. R+L appealed the determination that the amendments made during reexamination resulted in a substantive change in claim scope. The Federal Circuit affirmed, finding that amended claim 1 is not “substantially identical” to original claim under 35 U.S.C. 252, so R+L is not entitled to infringement damages prior to issuance of the reexamination certificate. View "R+L Carriers, Inc.. v. Qualcomm, Inc." on Justia Law

Magnetar filed suit alleging that Intamin maliciously prosecuted a patent infringement action against it and claiming that Intamin prosecuted the action even though the ‘350 Patent was invalid pursuant to the on-sale bar of 35 U.S.C. 102 (on-sale bar). The district court granted summary judgment to Intamin. The court concluded that a reasonable attorney could have determined that the on-sale bar did not apply due to the genuine dispute concerning whether the magnetic braking system had been (1) offered for sale before the critical date; and (2) was ready for patenting before the critical date. Therefore, the court affirmed as to this issue. The court also affirmed the district court's conclusion that Magnetar has not alleged sufficient facts to show a causal antitrust injury stemming from Intamin’s actions. Finally, the court concluded that the district court properly refused to sanction Magnetar for filing a frivolous action where Magnetar proceeded in good faith in not admitting facts related to the antitrust injury. Accordingly, the court affirmed the district court's judgment in its entirety. View "Magnetar Techs. v. Intamin, Ltd." on Justia Law

The three patents at issue share the same written description and explain that medical implements, such as catheters and luer ports, are common sites for transmissions of pathogens into patients. To prevent such transmissions, medical staff traditionally swabbed a site before making connections to medical implements. Swabs came in a small pad of cotton gauze soaked in a cleaning agent (e.g., isopropyl alcohol) and packed in a foil package to prevent evaporation. After swabbing, the site is allowed to dry, killing any pathogens. In practice, these swabbing procedures were often “overlooked” or “poorly executed.” The inventors provided a cleaning device that includes a cap that twist on to the medical implements and, when used, reliably disinfects a medical implement. In an infringement suit, the district court granted summary judgment of invalidity, finding the asserted claims obvious under 35 U.S.C. 103. The Federal Circuit reversed. The patent holder established a genuine dispute over whether one of ordinary skill in the art would have been motivated to add a vent to the disinfecting cap described in prior art. View "Ivera Med. Corp. v. Hospira, Inc." on Justia Law