The Technology & Information Law Blog

Analysis by Charles Gideon Korrell

  • JPMorgan v. Argus: DTSA Ownership, Regulatory Data, and the Territorial Limits of State Trade-Secret Law

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    JPMorgan Chase Bank’s trade-secret case against Argus Information & Advisory Services has now produced two merits opinions that expose an important divide between federal and state trade-secret protection for data moving through regulatory and commercial channels. In February 2025, the District of Delaware held that JPMorgan plausibly stated a claim under the federal Defend Trade…

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  • Deltona v. NOCO: Keyword Bidding, Source Confusion, and the Limits of Trademark Control

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    The Eleventh Circuit’s published decision in Deltona Transformer Corp. v. The NOCO Co., No. 24-13590 (11th Cir. Aug. 4, 2026), does more than add another appellate case on competitive keyword advertising. It separates several questions that Internet trademark cases often collapse: whether buying a rival’s mark as an advertising trigger is actionable trademark use, whether…

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  • Versata v. Ford: Modified Opinion Clarifies Review of $82 Million Contract Verdict

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    The Federal Circuit has modified its precedential opinion in Versata Software, LLC v. Ford Motor Co., Case Nos. 2024-1140, 2024-1206, and 2024-1234, without changing the judgment. The September 10, 2026 modification leaves intact the court’s trade-secret holdings, its order for a new trial on trade-secret damages, and its reinstatement of an $82.26 million breach-of-contract verdict.…

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  • Medical Imaging & Technology Alliance v. Library of Congress: D.C. Circuit Upholds DMCA Medical-Device Repair Exemption; Copyright Does Not Automatically Protect Repair Revenue

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    Manufacturers of software-enabled equipment often make substantial revenue after the initial sale through maintenance, diagnostics, and repair. Technological access controls can help preserve that business by limiting who can reach the software embedded in the product. In Medical Imaging & Technology Alliance v. Library of Congress, No. 25-5328 (D.C. Cir. Sept. 1, 2026), the D.C.…

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  • Praxis v. Goldstein: Patent Disclosure and the Limits of Early Trade Secret Dismissal

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    For technology companies that patent foundational technology while continuing confidential research and development, the difficult question is not whether a patent disclosure is public. It is how far that disclosure reaches. The District of Delaware’s September 3, 2026 decision in Praxis Precision Medicines, Inc. v. Goldstein, No. 1:25-cv-01256-JCG (D. Del. Sept. 3, 2026), illustrates why…

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  • Netlist v. Micron: Federal Circuit Affirms PTAB Obviousness Ruling, Leaves Extra-Petition Prior Art Question Open

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    The Federal Circuit’s precedential decision in Netlist, Inc. v. Micron Technology, Inc., No. 24-1707 (Fed. Cir. Sept. 2, 2026), affirmed the Patent Trial and Appeal Board’s determination that all challenged claims of a computer-memory patent were obvious, while leaving unresolved an important question about how far the Board may rely on prior art that was…

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  • Exelixis v. MSN Labs: Federal Circuit Upholds Crystalline Salt Genus Under § 112 Written Description

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    The Federal Circuit’s precedential decision in Exelixis, Inc. v. MSN Laboratories Private Ltd., Case No. 25-1236 (Fed. Cir. Aug. 31, 2026), affirmed a bench-trial finding that patents claiming crystalline cabozantinib (L)-malate satisfied the written-description requirement even though the specification expressly characterized only two crystalline polymorphs. The court concluded that the chemical name and formula of…

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  • Constellation Designs v. LG: Federal Circuit Draws Section 101 Line Between Optimization Claims and Specific Signal Constellations

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    The Federal Circuit’s decision in Constellation Designs, LLC v. LG Electronics Inc., No. 24-1822 (Fed. Cir. Aug. 31, 2026), draws an unusually clear line under 35 U.S.C. § 101 between claiming a technological objective and claiming a particular technological implementation. The court held claims broadly covering signal constellations “optimized” for improved capacity patent ineligible, while…

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  • AML IP v. Bath & Body Works Direct: Federal Circuit Allows Section 101 Dismissal After Finding Patent Venue Improper

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    The Federal Circuit’s decision in AML IP, LLC v. Bath & Body Works Direct, Inc., Case No. 2025-1280 (Fed. Cir. Aug. 28, 2026), holds that a district court may, in appropriate circumstances, decide a fully briefed merits defense even after concluding that patent venue is improper. Because venue is a waivable protection belonging to the…

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  • T-Mobile US v. KAIFI: Patent Settlement Dispute Falls Outside Federal Circuit Jurisdiction

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    The Federal Circuit’s precedential decision in T-Mobile US, Inc. v. KAIFI LLC, Case No. 2025-1006 (Fed. Cir. Aug. 28, 2026), draws an important boundary between patent litigation and commercial disputes involving patents. A state-law contract claim does not fall within the Federal Circuit’s exclusive appellate jurisdiction merely because one party’s preferred interpretation would require deciding questions of prosecution…

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