Justia Patents Opinion Summaries

The patents describe a networked system of gaming machines. The district court entered summary judgment, finding that that defendant's use of promotions to provide incentives for use of certain gaming machines infringed certain claims. The district court correctly construed claims referring to "issuing a command over the network to one of said preselected gaming devices responsive to a predetermined event; and paying at said one gaming device in accordance with the command." View "IGT v. Bally Gaming Int'l, Inc." on Justia Law

Plaintiff manufactures accessories for small arms weaponry, including handguards that attach to military rifles. Defendant, a distributor who became an employee, signed a nondisclosure agreement, and became familiar with all of plaintiff's products before he was terminated and went into competition with plaintiff. Plaintiff claimed patent infringement and misappropriation of trade secrets. The Federal Circuit affirmed the district court holding that the patent at issue, covering a sleeve for a handgun, was invalid for failing to meet the written description and best mode requirements. Plaintiff introduced sufficient evidence to support a verdict in its favor on Massachusetts law trade secret claims. The district court erred in denying a motion for mistrial and did not take adequate steps to determine whether the presence of a clamp, brought to the jury room by a juror, had a prejudicial effect. View "Atlantic Research Mktg. Sys., Inc. v. Troy" on Justia Law

The company's patent covers polyol-based resin blends and methods of using them to create closed-cell polyurethane and polyisocyanurate-based foams, used for thermal insulation boards for the walls of homes and buildings. On reexamination, the examiner ruled that all the claims were invalid as anticipated under 35 U.S.C. 102(b) or, in the alternative, obvious under 35 U.S.C. 103(a). The Board affirmed, relying upon the identical prior art references the examiner had cited. The Federal Circuit vacated, holding that the Board relied on new findings of fact to support rejection and failed to identify this rejection as a new ground, so that the company's notice rights were violated (5 U.S.C. 554(b)(3); 35 U.S.C. 6(b). Had the Board labeled its rejection as a new ground of rejection, the company could have reopened its prosecution to address the newly-alleged deficiencies in its Declaration with the examiner. View "In Re Stepan Co." on Justia Law

A manufacturer of cable connectors that are used to connect coaxial cables to electronic devices filed a complaint with the International Trade Commission asserting that the importation, sale for importation, and sale after importation of certain coaxial cable connectors infringed four of its patents and therefore violated 19 U.S.C. 1337. Its 539 design patent patent issued in 2001 and describes an ornamental design for a coaxial cable connector. The Commission ruled that the company failed to satisfy the requirement of showing that a "domestic industry" exists or was being established. The Federal Circuit affirmed. The company's enforcement litigation expenses did not constitute "substantial investment in exploitation" of the 539 patent. Those costs were not sufficiently related to licensing. The company has no formal licensing program and the litigation opponent was its only licensee. View "John Mezzalingua Assocs., Inc. v. Int'l Trade Comm'n" on Justia Law

The patent, entitled "Low Friction Rotary Knife," is directed to a power operated knife used principally in the meat packing and other commercial food processing industries. While plaintiff's claim of invalidity, asserting anticipation in its pre-1998 prior art blades, was pending, defendant sought reexamination. The validity of the claims was affirmed. The district court rejected a claim of invalidity, but found no infringement. The Federal Circuit affirmed denial of judgment as a matter of law on the issue of anticipation and affirmed with respect to infringement. The district court had excluded references and denied a new trial on the issue of obviousness, based on its interpretation of 35 U.S.C. 315(c)'s reference to "final determination." The Federal Circuit vacated and remanded that decision. View "Bettcher Indus., Inc. v. Bunzl USA, Inc." on Justia Law

In 1992 two companies began a joint venture to develop peptide compounds. The agreement provides that inventions created by joint efforts are jointly owned, but inventions attributable to a single party are owned by that party and that disputes will be arbitrated. In court-ordered arbitration, a panel decided that a certain group of patents are jointly owned, but that another group is owned by defendant. The district court confirmed those rulings, but vacated a ruling in defendant's favor on foreign patents. Holding that appeal is authorized by 9 U.S.C. 16(a)(1)(E), and that the dispute does not concern patent law, but is a contract issue, the Seventh Circuit reversed. The Federal Arbitration Act authorizes a court to vacate an award for any of four reasons, 9 U.S.C. 10(a); a conclusion that the arbitrators disregarded the law by failing to discuss the foreign patents separately from the domestic patents did not justify vacating the award. The judge mistakenly inferred from silence that the arbitrators must have had an extra-contractual ground; the arbitrators had no reason to discuss the foreign patents separately from the domestic patents. View "Affymax, Inc. v. Ortho-McNeil-Janssen Pharmaceuticals, Inc." on Justia Law

Defendant's process patent is directed to methods for preventing the contamination of exposed semiconductor chip terminals during encapsulation of the chips in molded plastic. Plaintiff, one of defendant's licensees, sought a declaration of non-infringement. The parties have been involved in other litigation. The district court dismissed for lack of subject matter jurisdiction. The Federal Circuit reversed. The dispute between the parties, as to whether the license agreement requires royalty payments to be tied to valid patent coverage, is sufficient to support declaratory judgment jurisdiction. View "Powertech Tech., Inc. v. Tessera, Inc." on Justia Law

Apple brought this action against Psystar for copyright infringement because Psystar was using Apple's software on Psystar computers. The district court held that Psystar was infringing Apple's federally registered copyrights in its operating software, Mac OS X, because Psystar was copying the software for use in Psystar's computers. Psystar subsequently appealed the district court's rejection of Psystar's copyright misuse defense, the district court's order enjoining Psystar's continuing infringement, and the district court's grant of Apple's motions to seal documents on grounds of maintaining confidentiality. The court held that Psystar's misuse defense failed because it was an attempt to apply the first sale doctrine to a valid licensing agreement. The court affirmed the district court's order enjoining Psystar's continuing infringement and Digital Millennium Copyright Act (DMCA), 17 U.S.C. 1203(b)(1), violations and held that the district court properly applied the Supreme Court's four eBay Inc. v MercExchange, L.L.C. factors. The court held, however, that there was no adequate basis on the record to support the sealing of any Apple records on grounds of confidentiality and applied the presumption in favor of access, vacating the district court's sealing orders. View "Apple Inc. v. Psystar Corp." on Justia Law

The patents at issue relate to balloon-expandable stents, used to treat occluded blood vessels. Following a remand, the district court found that defendants did not literally infringe the patents and rejected claims that the patents were invalid for lack of description or due to inequitable conduct. The Federal Circuit affirmed. Based on the court's proper clarification of its construction of the term "undulating," there was not substantial evidence to support a finding of infringement, nor was there substantial evidence of inequitable conduct. View "Cordis Corp. v. Boston Scientific Corp." on Justia Law

Plaintiff owns the 245 Patent, which originally issued in 2005 and claims p-GlcNAc, a polymer extracted from another polymer called chitin, that accelerates hemostasis (the process which causes bleeding to stop) and is useful in trauma units for treating serious wounds. The district court found infringement. While the case was pending, the patent was re-examined; the scope of the claims changed. The Federal Circuit vacated an injunction and award of damages and remanded. Defendant has absolute intervening rights with respect to products manufactured before the date of reissue. The court must determine whether defendant has equitable intervening rights with respect to products manufactured after the date of reissue. A contention that the patent, as originally issued, was invalid is moot. View "Marine Polymer Tech., Inc. v. Hemcon, Inc." on Justia Law