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 v. Seagate Tech., Nos. 2016-1749, 2016-1751, and 2016-2039 (September 6, 2017) (nonprecedential) (3-0) Patent No. 7,900,057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Smartdoor Holdings, Inc. v. Edmit Industries, Inc., No. 2016-2152 (September 7, 2017) (nonprecedential) (3-0) Patent No. 6,484,784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Edge Systems LLC v. Aguila, Nos. 2016-2189, 2016-2384, and 2017-1030 (September 8, 2017) (nonprecedential) (3-0) Patent Nos. 6,299,620, 6,641,591, 7,678,120, 7,789,886, 8,066,716, and 8,337,513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.”