October 9, 2017

Federal Circuit Court Decisions For Week Ending September 9, 2017

Enova Tech. Corp. v. Seagate Tech., Nos. 2016-1749, 2016-1751, and 2016-2039 (September 6, 2017) (nonprecedential) (3-0) Patent No. 7,900,057

Key point(s):

  • Sales, licenses, and industry praise advanced as objective indicia of nonobviousness must be clearly linked to the claims.

Lifetime Industries, Inc. v. Trim-Lok, Inc., No. 2017-1096 (September 7, 2017) (precedential) (3-0) Patent No. 6,996,590

Key point(s):

  • Sale of a part of a claimed apparatus can be an inducement to infringe, if the part is not suitable for substantial noninfringing use.

Intercontinental Great Brands v. Kellogg N. Am. Co., Nos. 2015-2082 and 2015-2084 (September 7, 2017) (precedential) (2-1) Patent No. 6,918,532

Key point(s):

  • A motivation to combine analysis may not require expert testimony, if the technologies and prior art are simple enough.
  • While an obviousness conclusion requires consideration of objective indicia (such as commercial success and industry praise), a motivation to combine analysis is not required to consider those objective indicia.

Smartdoor Holdings, Inc. v. Edmit Industries, Inc., No. 2016-2152 (September 7, 2017) (nonprecedential) (3-0) Patent No. 6,484,784

Key point(s):

  • The Federal Circuit will not overturn a decision by the PTAB on an IPR without a clear showing of error in the PTAB’s reasoning.

Edge Systems LLC v. Aguila, Nos. 2016-2189, 2016-2384, and 2017-1030 (September 8, 2017) (nonprecedential) (3-0) Patent Nos. 6,299,620, 6,641,591, 7,678,120, 7,789,886, 8,066,716, and 8,337,513

Key point(s):

  • Failure to take any depositions renders an order reducing the number of allowed depositions merely “harmless error.”

Related Team: