April 19, 2016

Federal Circuit Court Decisions For Week Ending April 1, 2016

Romag Fasteners, Inc. v. Fossil Inc., Nos. 2014-1856, 2014-1857, (March 31, 2016) (Precedential) (3-0) U.S. Patent No. 5,722,126

Key point(s):

  • Laches remains a defense to legal relief in a patent infringement case.
  • Trademark infringement must be willful to trigger profit awards in the Second Circuit. 

Clare v. Chrysler Group LLC, No. 2015-1199, (March 31, 2016) (Precedential ) (3-0) U.S. Patent Nos. 6,499,795; 7,104,583

Key point(s):

  • A determination that a claim term “needs no construction” or has the “plain and ordinary meaning” may be inadequate when a term has more than one “ordinary” meaning or when reliance on a term’s “ordinary” meaning does not resolve the parties’ dispute. 

ClearCorrect Operating, LLC v. International Trade Commission, No. 2014-1527, (April 1, 2016) (Precedential ); Order

Key point(s):

  • The term “articles” under 19 U.S.C. § 1337 (“Section 337 of the Tariff Act”) is limited to “material things” and thus the ITC has no jurisdiction to block importation of electronic transmissions (e.g., digital files that enter the U.S. electronically) that infringe U.S. patents.   

Microsoft Corp. v. Geotag Inc., No. 2015-1140, (April 1, 2016) (Precedential) (3-0); U.S. Patent No. 5,930,474

Key point(s): 

  • Where a complaint and a counterclaim both raise issues arising under federal patent law, a district court may retain subject matter jurisdiction over the counterclaim pursuant to 28 U.S.C. § 1338(a), even if the district court later dismisses or finds a defect in the complaint. 

SimpleAir, Inc. v. Sony Ericsson Mobile Communications AB, No. 2015-1251, (April 1, 2016) (Precedential) (3-0); U.S. Patent No. 7,035,914

Key point(s):

  • When infringement relies on an incorrect claim construction, and no reasonable jury could have found infringement under the proper claim construction, the district court’s determination may be reversed with respect to JMOL without remand.

Related Team: