Federal Circuit Court Decisions For Week Ending April 22, 2016
Sport Dimension, Inc., v. The Coleman Company, Inc., No. 2015-1553, (April 19, 2016) (precedential) (3-0) Design Patent No. D623,714
Key point(s):
- Where a design patent claim includes both functional and design elements, the scope of the claim must be construed in order to identify the non-functional aspects of the design.
In re Brown, No. 2015-1852 (April 22, 2016) (non-precedential) Patent Application No. 09/795,210
Key point(s):
- A patent-eligible claim needs more than an “application” step to transform an abstract idea into a patent-eligible concept.
Robert Mankes v. Vivid Seats Ltd., No. 2015-1500, -1501, -1901, No. 2015-1909 (April 22, 2016) (precedential) (3-0) Patent No. 6,477,503
Key point(s):
- The latest standard for determining liability in a divided infringement case is considerably broader than the previous standards that required direct infringement by at least one person.
Target Training International, Ltd. v. Extended DISC North America, Inc., No. 2015-1873, 2015-1908 (April 22, 2016) (non-precedential) Patent No. 7,249,372
Key point(s):
- Res judicata does not apply to bar the assertion of new claims acquired during the pendency of a litigation that could have been, but were not litigated or adjudicated in the action.
- If newly acquired claims are not substantively identical in scope to the original claims, then recovery could only be had for the period following the acquisition of the new claims.