CAFC News Brief

Fintiv, Inc. v. Apple Inc., decided May 16, 2025

This nonprecedential court opinion from the United States Court of Appeals for the Federal Circuit concerns an appeal by Fintiv, Inc. against Apple Inc. regarding alleged infringement of a patent related to mobile wallets and associated software, termed "widgets." Fintiv had sued Apple, claiming that Apple's products using Apple Pay and Apple Wallet infringed on their patent. The core issue at the district court level, and the focus of this appeal, was the interpretation and identification of a "widget" within Apple's technology, as defined by the patent. The Appeals Court reversed the lower court's summary judgment in favor of Apple, finding that Fintiv presented sufficient circumstantial evidence to raise a genuine dispute regarding the existence of a widget, and remanded the case for further consideration of related claim limitations and other potential grounds for summary judgment. Full case summary here: https://www.cafcnewsbriefs.com/post/fintiv-inc-v-apple-inc-decided-may-16-2025

Yoldas Askan v. FARO Technologies, Inc., decided May 12, 2025

This nonprecedential appellate opinion from the United States Court of Appeals for the Federal Circuit addresses Yoldas Askan's appeal of a district court's dismissal of his patent infringement lawsuit against FARO Technologies, Inc. The court affirms the district court's decision to dismiss the complaint with prejudice for failure to state a plausible claim, finding that Askan's pleadings were conclusory and lacked sufficient factual allegations of infringement. The opinion also confirms the district court's discretion to reconsider its judgment and its authority to strike FARO's answer to the complaint. Finally, the court upheld the district court's refusal to allow discovery to enable Askan to gather information needed to plead a plausible claim. Full case summary here: https://www.cafcnewsbriefs.com/post/yoldas-askan-v-faro-technologies-inc-decided-may-12-2025

Incyte Corporation v. Sun Pharmaceutical Industries, Ltd., decided May 7, 2025

This appeal concerns a preliminary injunction previously granted by the United States District Court for the District of New Jersey, which prevented Sun Pharmaceutical from launching its drug Leqselvi. The core of the dispute involves Incyte's claim of patent infringement related to its patent on deuterated ruxolitinib, a drug used to treat autoimmune disorders, and Sun Pharmaceutical's launch of a similar product for alopecia areata. The appellate court focuses on whether the district court correctly found irreparable harm to Incyte, ultimately reversing the preliminary injunction based on a finding that Incyte would not be the first to market regardless of Sun Pharmaceutical's actions due to Incyte's product development timeline. Full case summary here: https://www.cafcnewsbriefs.com/post/incyte-corporation-v-sun-pharmaceutical-industries-ltd-decided-may-7-2025-precedential

IOENGINE v. Ingenico, decided May 7, 2025

IOENGINE is challenging a jury verdict from the District of Delaware that found certain claims of IOENGINE's patents related to portable devices invalid based on prior art. Specifically, IOENGINE appeals the finding that the DiskOnKey System, including its Firmware Upgrader, was in public use before the invention date, which invalidates their patents. IOENGINE also contested the district court's jury instructions and the allowance of certain prior art at trial. The court affirms the district court's decision, concluding that substantial evidence supported the jury's finding of public use and that the jury instructions were proper. The court also clarifies that Inter Partes Review (IPR) estoppel does not prevent a party from asserting invalidity grounds in district court based on prior art that could not have been raised in the IPR proceeding, such as public use or on sale grounds.  Written case summary here: https://www.cafcnewsbriefs.com/post/ioengine-v-ingenico-decided-may-7-2025

Jazz Pharmaceuticals v. Avadel CNS Pharmaceuticals, decided May 6, 2025

The core of the dispute involves Avadel's product, Lumryz, and whether the district court correctly issued a permanent injunction preventing Avadel from engaging in certain activities related to it, specifically concerning its patent U.S. Patent 11,147,782. The appeals court addressed three distinct enjoined activities: initiating new clinical trials, offering open-label extensions in ongoing trials, and applying for FDA approval for new indications of Lumryz, ultimately reversing the injunction on the first two grounds and vacating and remanding the third for further consideration based on the legal interpretation of 35 U.S.C. § 271(e)(2) and the applicability of the Hatch-Waxman Act's safe harbor provision. The decision focuses on the limitations on injunctive relief for certain activities related to FDA submissions and clinical trials under patent law.

Aviation Capital Partners v. SH Advisors: Patent Eligibility, decided May 6, 2025

STR is appealing a decision from the District Court for the District of Delaware, which dismissed their patent infringement lawsuit. The district court ruled that the asserted claims of STR's '988 patent, which concerns a system and method for determining the taxability status of an aircraft, were invalid because they were directed to an abstract idea without an inventive concept. The Court of Appeals affirmed the district court's decision, agreeing that the claims were abstract and lacked sufficient novelty, noting that the method of collecting and analyzing data and using common sense principles did not constitute an inventive concept under 35 U.S.C. § 101. Written case summary here: https://www.cafcnewsbriefs.com/post/aviation-capital-partners-v-sh-advisors-patent-eligibility-decided-may-6-2025.

April 2025 Month in Review - CAFC Patent Cases

Topics covered include prosecution history disclaimer and its interaction with litigation stipulations in a Hatch-Waxman case (Azurity v. Alkem), the analysis of patent eligibility under 35 U.S.C. § 101, particularly for software and image processing claims focusing on the requirement for specific "how" details beyond abstract ideas (Longitude Licensing v. Google), induced infringement in the context of ANDA filings and the weight given to drug label instructions versus other evidence (Metacel v. Rubicon), and design patent infringement, emphasizing the importance of the ordinary observer test and plain dissimilarity based on ornamental features at the summary judgment stage (North Star Technology v. Latham Pool Products). Finally, one source discusses the procedural challenges of seeking relief from a final judgment under Rule 60(b), highlighting the critical role of timeliness and preserving arguments during initial proceedings and appeals (Wakefield v. Blackboard).

Geoscope Technologies Pte. Ltd. v. Google LLC & Apple Inc., decided May 2, 2025

Geoscope alleged that Google and Apple infringed on several of its patents related to determining the location of mobile devices. The district court had found the patents were directed to patent ineligible subject matter as abstract ideas. The Federal Circuit affirms the district court's decision, concluding that the patent claims, while describing comparing data from known and unknown locations to determine location, lack an inventive concept beyond the abstract idea of collecting, organizing, and analyzing data using existing technology. The court found the claims relied on generic functional language and did not specify novel techniques or technology for improving geolocation.

Fintiv, Inc. v. PayPal Holdings, Inc.. decided April 30, 2025

The core issue revolves around the interpretation of certain terms within Fintiv's patents related to a "payment handler" or "payment handler service" in a cloud-based transaction system. The District Court had previously ruled these terms indefinite, finding they recited functions without disclosing sufficient structure as required by patent law, specifically under 35 U.S.C. § 112 ¶ 6. The Federal Circuit reviews the lower court's decision, ultimately affirming that the payment-handler terms invoke this section of law and that the patent specifications lack the necessary structural or algorithmic details, leading to the claims being deemed invalid due to indefiniteness.
Detailed case summary here

LONGITUDE LICENSING LTD. v. GOOGLE LLC, decided April 30, 2025

Longitude appealed the dismissal by the Northern District of California of its lawsuit against Google for infringement of four patents related to digital image correction. The district court had found the patents ineligible under 35 U.S.C. § 101, a decision the Federal Circuit affirmed. Applying the two-step Alice framework, the court agreed the claims were directed to the abstract idea of adjusting image quality based on the main object, lacking an inventive concept.
Detailed case summary here