Lone Star v. Nanya Technology Corp., No. 2018-1581 (May 30, 2019)(precedential 3-0) (Patent No. 5,872,038; 6,097,061; 6,103,611; 6,326,231; and 6,388,330)

Key point(s):

• A party’s ability to sue in its own name turns on whether an agreement transferred all substantial rights to the patents to the party.
• 35 U.S.C. § 281 does not implicate a court’s subject matter jurisdiction, but rather places restrictions on who may obtain relief for patent infringement.
• Before dismissing a case for failure to join a necessary party, a district court must consider whether the necessary party could have been joined under Fed. R. Civ. P. 19.

Cobalt Boats v. Brunswick Corp., No. 2018-1376 (May 31, 2019) (nonprecedential), (Patent No. 8,375,880)

Key point(s):

• Where a precise value is included in the claim without a term such as “about,” the claim language is interpreted as imposing a strict numerical boundary.
• Prosecution history estoppel restricts how broadly a claim extends under the doctrine of equivalents.