March 15, 2024

Federal Circuit Summary for Week Ending March 15, 2024

Deadalus Blue LLC v. Vidal, No. 2023-1313 (March 13, 2024) (nonprecedential)

Key point(s):

  • A reference is analogous art if it is either in the same “field of endeavor” or “reasonably pertinent to the particular problem with which the inventor is involved.”

Tube-Mac Industries, Inc. v. Campbell, No. 2022-2170 (March 15, 2024) (nonprecedential)

Key point(s):

  • Without a definite and firm conviction that a mistake has been made by the district court in concluding that alleged joint inventors contributed significantly to the conception of the claimed invention, affirmance is appropriate under the “clear error” standard.

SharkNinja Operating LLC v. iRobot Corp., No. 2023-1151 (March 15, 2024) (nonprecedential)

Key point(s):

  • When claim construction arises from the claim language itself, that it is consistent with the embodiments does not mean it improperly imports limitations from the specification.
  • A mere reference to the placement of a claim element as “simply a design choice” in the petition does not establish a sufficient motivation to modify the structure in the prior art.

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Jay Yates

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