CAFC News Brief

North Star Technology International LTD. v. Latham Pool Products, Inc., decided April 24, 2025

North Star sued Latham Pool Products for allegedly infringing its design patent for a rectangular swimming pool with tanning ledges. The district court granted summary judgment for Latham, finding the pool designs plainly dissimilar. Specifically, the court noted North Star's design used straight, geometric shapes, while Latham's featured rounded, curved elements. The Federal Circuit Court of Appeals affirmed this decision, agreeing that an ordinary observer would not mistake one pool for the other. The appellate court also emphasized that design patents protect only ornamental, non-functional aspects and cannot monopolize common design elements. Finally, the court found no error in the district court's evidentiary rulings and upheld the non-infringement finding.  Full case summary

Wakefield v. Blackboard, decided April 23, 2025

This case concerns Franz A. Wakefield's appeal of the District Court's denial of his motion for relief from a prior judgment of patent invalidity against several technology companies. Wakefield's initial patent infringement suit regarding U.S. Patent No. 7,162,696 was previously decided against him. He subsequently filed a motion under Federal Rule of Civil Procedure 60(b), arguing that claims within the patent should have been considered differently and raising concerns about a judge on the appellate panel. The Federal Circuit affirmed the District Court's decision, finding that Wakefield's motion was untimely and that the District Court did not abuse its discretion in denying his requests. The court also addressed and rejected Wakefield's arguments regarding a rehearing. Full case summary

Metacel v. Rubicon, decided April 23, 2025

Metacel accused Rubicon of inducing infringement of its patent (U.S. Patent 10,610,502) for an oral baclofen solution stored at refrigerated temperatures. The core issue was whether Rubicon's proposed label for its generic version, which primarily instructed room temperature storage but permitted refrigeration, would lead users to infringe Metacel's patent. The court affirmed the district court's summary judgment of no infringement, reasoning that Rubicon's label did not encourage the patented storage method. Full case summary

Recentive Analytics v. Fox Corp., decided April 18, 2025

Recentive sued Fox for infringing four of its patents related to using machine learning to generate network maps and event schedules for television broadcasts and live events. The district court initially dismissed the case, finding Recentive's patents claimed ineligible subject matter under patent law. The Federal Circuit affirmed this dismissal, concluding that the patents merely described the application of generic machine learning techniques to a specific field without demonstrating any inventive improvement to the technology itself. The court determined that applying existing technology to a new data environment or achieving faster results does not automatically confer patent eligibility. Full case summary

WSOU Investments LLC (Brazos) v. F5, Inc., decided April 17, 2025

This Federal Circuit opinion addresses an appeal by WSOU Investments LLC (Brazos) against F5, Inc. regarding a patent for network traffic distribution. The dispute centered on the interpretation of the term "master device" within the patent claims. The district court had adopted Brazos's proposed construction during claim construction but later granted summary judgment of noninfringement to F5. Brazos appealed this decision, arguing for a new interpretation of "master device" that differed from its earlier stance. The Federal Circuit found that Brazos had forfeited this new argument by not presenting it to the district court. Consequently, the appellate court affirmed the district court's summary judgment, holding Brazos to its previously advocated claim construction.

Azurity Pharmaceuticals, Inc. v. Alkem Laboratories Ltd., decided April 8, 2025

Azurity's U.S. Patent No. 10,959,948 relates to a liquid vancomycin formulation. The appeal follows a district court ruling that Alkem's Abbreviated New Drug Application (ANDA) for a generic version did not infringe Azurity's patent. The central issue revolved around whether Azurity disclaimed the inclusion of propylene glycol during the patent's prosecution. The court affirmed the lower court's decision, finding that Azurity did clearly disclaim propylene glycol, and because Alkem's proposed generic product contains it, no infringement occurred.

AMS-OSRAM v. Renesas, decided April 4, 2025

This Federal Circuit opinion details a long-standing legal battle between AMS-OSRAM and Renesas regarding misappropriated trade secrets for ambient-light sensor technology used in electronics. The court reviews appeals from both parties concerning monetary awards for trade secret misappropriation and breach of a confidentiality agreement. While the court adjusts the date when the trade secret was considered publicly accessible, it largely upholds the district court's rulings on damages, including disgorgement of profits and exemplary damages. However, the court identifies errors in the calculation of prejudgment interest and remands that specific issue for further consideration.

Express Mobile v. GoDaddy, decided April 2, 2025

Express Mobile sued GoDaddy for infringing five of its patents related to website building and display technologies. The district court initially ruled in favor of GoDaddy, granting summary judgment of noninfringement for two patents (the '397 family) based on its claim construction and a jury finding of noninfringement for the other three ('755 family). On appeal, the Federal Circuit reversed the district court's interpretation of a key phrase in the '397 family patents, vacating the summary judgment and sending that part of the case back for further proceedings. However, the appellate court upheld the jury's verdict of noninfringement and the denial of post-trial motions for the '755 patent family, finding sufficient evidence supported the jury's decision. Thus, the case has been partially reversed, partially affirmed, and remanded for additional litigation on specific patent claims.

Janssen Pharmaceuticals, Inc. v. Mylan Laboratories Ltd, decided March 28, 2025

Janssen sued Mylan for allegedly inducing patent infringement through its proposed generic drug labels for a treatment of missed doses of Janssen's schizophrenia medication, Invega Trinza. The district court found in favor of Janssen, determining that Mylan would likely induce healthcare providers to infringe Janssen's patent and that Mylan failed to prove the patent was invalid. Mylan appealed this decision, arguing against the findings of induced infringement and nonobviousness of the patent. The Court of Appeals ultimately affirmed the district court's decision, finding Mylan's arguments unpersuasive on both issues.

Roland Corporation v. inMusic Brands, Inc., decided March 27, 2025

This Federal Circuit opinion documents an appeal and cross-appeal in a patent infringement lawsuit between Roland Corporation and inMusic Brands concerning electronic drums and cymbals. Roland initially sued inMusic for infringing eight patents. The district court granted partial summary judgment of non-infringement, and a jury subsequently found the remaining patents infringed. Both parties appealed aspects of the district court's rulings, including claim construction, expert testimony, infringement findings, validity, damages, equitable estoppel, and prejudgment interest. The Federal Circuit affirmed some findings, reversed others, vacated the damages award, and remanded for a new trial on damages, finding errors in the calculation of both lost profits and reasonable royalties, while also addressing the denial of prejudgment interest.