CAFC News Brief

DNA Genotek Inc. v. Spectrum Solutions LLC, decided 14 Feb 25

This case is about an appeal by DNA Genotek Inc. against a district court's ruling of non-infringement in a patent dispute with Spectrum Solutions LLC. The case revolves around U.S. Patent No. 10,619,187, which covers devices and methods for preserving nucleic acids. The core issue is the interpretation of the term "reagent compartment" within the patent's claims. The lower court construed this term to mean a region within the containment vessel, a construction Genotek disputes. The Court of Appeals ultimately affirms the lower court's construction, finding support in the patent's specification and prosecution history. The court concluded that Genotek had limited the patent's scope by intentionally omitting a design with the reagent in the cap.

Kroy IP Holdings, LLC v. Groupon, Inc., decided 10 Feb 25

Kroy IP Holdings, LLC sued Groupon, Inc. for patent infringement. Groupon moved to dismiss, arguing collateral estoppel based on prior Patent Trial and Appeal Board (PTAB) decisions finding other claims of the same patent unpatentable. The district court granted the motion, but the Federal Circuit reversed. The court found that the different burdens of proof between PTAB proceedings (preponderance of the evidence) and district court (clear and convincing evidence) prevented collateral estoppel from applying. Therefore, the case was remanded for further proceedings.

Trudell Medical International Inc. v. D R Burton Healthcare, LLC, decided 07 Feb 25

In Trudell Medical International Inc. v. D R Burton Healthcare, LLC, the court reversed the district court's decision to admit expert testimony from a Dr. Collins due to procedural violations and unreliability. Consequently, the appeals court vacated the jury's finding of non-infringement and remanded the case for a new trial. Furthermore, the appellate court affirmed the denial of a judgment as a matter of law but ordered reassignment of the case to a different district court judge due to concerns about the original judge's impartiality. The ruling centered on the admissibility of Dr. Collins' expert testimony and its impact on the trial's fairness and outcome.

Regeneron Pharmaceuticals, Inc. v. Mylan Pharmaceuticals Inc., Samsung Bioepis Co., Ltd., Et Al., decided 29 Jan 25

Regeneron Pharmaceuticals, holding patents for its drug EYLEA®, sued Samsung Bioepis and other companies for patent infringement after they filed applications to market biosimilars. The appeals court upheld the lower court's assertion of personal jurisdiction over Samsung Bioepis, a South Korean company, based on its nationwide marketing plans. The court also found that Regeneron demonstrated a likelihood of success on the merits and irreparable harm if the injunction wasn't granted, thus affirming the preliminary injunction. The court's decision centered on the patentability of Regeneron's claims and Samsung Bioepis's failure to raise substantial questions of invalidity.

Regeneron Pharmaceuticals, Inc. v. Formycon AG, decided 29 Jan 25

This non-precedential opinion from the United States Court of Appeals for the Federal Circuit affirms a preliminary injunction against Formycon AG, preventing it from marketing a biosimilar to Regeneron's EYLEA® without a license. The court upheld the lower court's finding of personal jurisdiction over Formycon, despite its arguments regarding its business operations outside of West Virginia. The appeals court also rejected Formycon's challenges to the injunction based on alleged patent invalidity due to obviousness-type double patenting and insufficient written description. Finally, the court affirmed the lower court's conclusion that Regeneron demonstrated a causal link between potential infringement and irreparable harm. The decision largely relies on a nearly simultaneous, very similar case involving Samsung Bioepis.

Image Processing Technologies LLC v. LG Electronics Inc., decided 29 Jan 25

This non-precedential Federal Circuit opinion affirms a district court's claim construction in a patent infringement case. Image Processing Technologies (IPT) appealed the district court's interpretation of a claim term in U.S. Patent No. 6,959,293, arguing it was broader than the broadest reasonable interpretation applied by the Patent Trial and Appeal Board (PTAB). The Federal Circuit disagreed, finding the district court's construction consistent with the patent's intrinsic evidence (claims, specification, and prosecution history), and rejecting IPT's arguments regarding "common parameter" limitations. The court concluded that the district court correctly determined that the disputed claim term was not unduly broad, affirming the judgment for LG Electronics.

Huang v. Amazon.com, Inc., decided 28 Jan 25

This is a non-precedential opinion from the United States Court of Appeals for the Federal Circuit affirming a district court's dismissal of a patent infringement lawsuit filed by Xiaohua Huang against Amazon. Huang alleged that Amazon infringed his patents on ternary content addressable memory technology through the use of EEPROM chips in various products. The district court dismissed Huang's complaint and denied his motion to amend, finding his allegations too vague and conclusory to provide Amazon with adequate notice of the infringement claims. The appeals court agreed, concluding that Huang failed to sufficiently link specific accused products to the allegedly infringing chips, even after multiple attempts to amend his complaint. The court upheld the district court's decision based on established Ninth Circuit precedent regarding pleading requirements and motions for leave to amend.

Steuben Foods, Inc. v. Shibuya Hoppmann Corporation, decided 24 Jan 25

Steuben Foods sued Shibuya Hoppmann Corporation for infringing three of its patents related to aseptic food packaging. A jury found in favor of Steuben, awarding substantial damages. The District Court overturned the jury verdict via judgment as a matter of law (JMOL), granting a new trial conditionally. The Federal Circuit reversed the JMOL for two patents, reinstating the jury's verdict, and vacated the conditional new trial for the third patent. The court also addressed the conditional grant of new trials regarding invalidity and damages, remanding those for further proceedings.

Deere & Company v. AGCO Corp., Precision Planting, LLC, decided 24 Jan 25

Deere & Company appealed a district court's denial of its post-trial motions for judgment as a matter of law (JMOL) and a new trial following a jury verdict finding no patent infringement against AGCO Corporation and Precision Planting, LLC. The dispute centered on Deere's patents for high-speed agricultural planting technology. The Federal Circuit affirmed the lower court's decisions, finding no abuse of discretion in denying the new trial motion and upholding the JMOL denial due to Deere's failure to properly request JMOL before the close of evidence. The court's decision also addressed Deere's arguments concerning evidentiary issues and claim construction, ultimately rejecting Deere's claims of error.

BearBox LLC v. Lancium LLC, decided 13 Jan 25

BearBox LLC sued Lancium LLC for patent infringement and conversion, alleging Lancium stole BearBox's Bitcoin mining technology. The District Court granted summary judgment to Lancium, finding the conversion claim preempted by federal patent law and that BearBox failed to prove Storms' inventorship of the disputed patent. The Federal Circuit affirmed, upholding the preemption ruling because the conversion claim essentially replicated a patent infringement claim. The court also affirmed the exclusion of BearBox's supplemental expert report due to its untimely submission and affirmed the denial of BearBox's inventorship claim due to insufficient evidence.