Year: 2025
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Agilent v. Synthego: Federal Circuit Clarifies Written Description and Motivation to Combine
The Federal Circuit vacated and reversed key findings by the PTAB in a suite of post-grant challenges brought against Agilent Technologies’ patents on CRISPR-related RNA purification methods. The decision in Agilent Technologies, Inc. v. Synthego Corp., Nos. 23-1916, -1917, -1918, -1919, and -2043, addresses recurring issues in PTAB proceedings: how to properly assess written description…
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Fraunhofer v. Sirius XM: CAFC Clarifies Limits of Equitable Estoppel in Patent Litigation
The Federal Circuit reversed a district court’s grant of summary judgment in Fraunhofer-Gesellschaft zur Förderung der angewandten Forschung e.V. v. Sirius XM Radio Inc., No. 23-2267, holding that disputed issues of fact precluded the application of equitable estoppel to bar Fraunhofer’s patent infringement claims. While the decision arises from a complex licensing history involving satellite…
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Dolby Laboratories Licensing Corp. v. Unified Patents, LLC: No Standing to Appeal IPR RPI Dispute
In Dolby Laboratories Licensing Corp. v. Unified Patents, LLC, No. 23-2110 (Fed. Cir. June 5, 2025), the Federal Circuit dismissed Dolby’s appeal for lack of Article III standing. Although Dolby had prevailed before the Patent Trial and Appeal Board (PTAB) in an inter partes review (IPR) initiated by Unified Patents, it sought to appeal the…
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La Molisana v. United States: Inaccuracies in Protein Labeling Undermine Commerce’s Antidumping Comparison Method
In La Molisana S.p.A. v. United States, the Federal Circuit issued a significant ruling that will reverberate across the antidumping landscape, particularly for food manufacturers and importers dealing with technical product classifications. The court held that the Department of Commerce’s methodology for comparing U.S. and foreign pasta products failed to comply with the statutory mandate…
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Alnylam Pharmaceuticals, Inc. v. Moderna, Inc.: Express Definitions in Patent Specs Can Limit Claim Scope
In Alnylam Pharmaceuticals, Inc. v. Moderna, Inc., No. 23-2357 (Fed. Cir. June 4, 2025), the Federal Circuit affirmed a claim construction that doomed Alnylam’s infringement case against Moderna’s COVID-19 vaccine. The decision reinforces the primacy of clear definitional language in a patent’s specification—even when it narrows claim scope beyond what a patentee may have intended.…
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V.O.S. Selections v. United States: CIT Rejects Presidential Tariffs Under IEEPA
On May 28, 2025, the U.S. Court of International Trade issued a major decision in V.O.S. Selections, Inc. v. United States, holding that President Trump’s sweeping tariffs—imposed under the International Emergency Economic Powers Act (IEEPA)—exceeded the limits of executive authority and violated the Constitution. The ruling vacates the tariffs and enjoins their enforcement, bringing them…
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Sigray, Inc. v. Carl Zeiss X-Ray Microscopy, Inc.: Inherent Anticipation Requires Full Scope of the Claim
In a decision clarifying the boundaries between claim construction and factual findings of inherency, the Federal Circuit in Sigray, Inc. v. Carl Zeiss X-Ray Microscopy, Inc., No. 23-2211 (Fed. Cir. May 23, 2025), reversed the PTAB’s determination that certain claims of U.S. Patent No. 7,400,704 were not anticipated by the prior art. The court concluded…
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Curtin v. United Trademark Holdings, Inc.: No Standing for Consumers to Oppose Trademark Registrations Absent Commercial Interest
In Curtin v. United Trademark Holdings, Inc., No. 23-2140 (Fed. Cir. May 22, 2025), the Federal Circuit affirmed the dismissal of a consumer’s opposition to a trademark registration, holding that an individual lacking a commercial interest does not have statutory standing under 15 U.S.C. § 1063 to oppose trademark registration. Applying the Lexmark zone-of-interests and…
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EcoFactor v. Google: En Banc Federal Circuit Tightens Daubert Review of Patent Damages Experts
In a closely watched en banc decision issued on May 21, 2025, the Federal Circuit reversed the district court’s denial of a new trial on damages in EcoFactor, Inc. v. Google LLC, No. 2023-1101. The court held that the trial court abused its discretion by admitting expert damages testimony that was not based on sufficient…
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In re: Vetements Group AG — Generic Foreign Terms Cannot Serve as Trademarks
In In re: Vetements Group AG, Nos. 2023-2050, -2051 (Fed. Cir. May 21, 2025), the Federal Circuit affirmed the Trademark Trial and Appeal Board’s (TTAB) refusal to register “VETEMENTS” as a trademark for clothing and online retail clothing store services. Applying the doctrine of foreign equivalents, the court agreed that “vetements,” the French word for…