Month: September 2024
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Federal Circuit Vacates District Court’s Surprise Patent Ineligibility Ruling in Astellas v. Sandoz
In a major rebuke to a district court’s handling of patent eligibility, the Federal Circuit has vacated a decision that invalidated Astellas’s pharmaceutical patent under 35 U.S.C. § 101—a ruling the lower court made on its own initiative, without either party raising the issue. The court’s strong reaffirmation of the “party presentation principle” signals a…
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Federal Circuit Overturns District Court’s Ruling on Indefiniteness in Teleflex v. Medtronic
In a significant decision for medical device patent litigation, the Federal Circuit vacated and remanded a district court’s ruling that had invalidated key claims in a patent dispute between Teleflex and Medtronic. The case centered on guide extension catheter technology used in cardiovascular procedures, with the core issue being whether the term “substantially rigid portion/segment”…
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Contour v. GoPro: POV Camera Claims Survive Section 101
In a significant development in the evolving landscape of patent eligibility, the Federal Circuit reversed a district court’s grant of summary judgment under 35 U.S.C. § 101, holding that claims directed to a point-of-view (POV) action camera with real-time streaming and control functionality recite patent-eligible subject matter. The September 9, 2024 decision in Contour IP…
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ParkerVision v. Qualcomm: Collateral Estoppel and Expert Exclusion in Patent Litigation
After more than a decade of litigation between ParkerVision and Qualcomm, the Federal Circuit has vacated summary judgment of non-infringement and reversed key Daubert rulings that had hobbled ParkerVision’s case. The court’s decision in ParkerVision, Inc. v. Qualcomm Inc., Nos. 2022-1755, 2024-2221 (Fed. Cir. Sept. 6, 2024), sheds new light on the proper application of…
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Osseo Imaging v. Planmeca: Rejection of Temporal Limitation on Expert Qualifications
In its September 2024 decision in Osseo Imaging, LLC v. Planmeca USA Inc., the Federal Circuit reaffirmed the standard for expert qualifications in patent cases, declining to impose a temporal requirement that an expert possess ordinary skill in the art as of the time of invention. The ruling has notable implications for litigation strategy, particularly…
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Broadband iTV v. Amazon: UI Claims Fail Section 101
In its recent decision Broadband iTV, Inc. v. Amazon.com, Inc., the Federal Circuit affirmed a summary judgment ruling that all asserted claims from five patents were directed to patent-ineligible subject matter under 35 U.S.C. § 101. The opinion, authored by Judge Reyna, offers a comprehensive application of the Alice two-step framework and reiterates that automation…