The Technology & Information Law Blog

Analysis by Charles Gideon Korrell

  • V.O.S. Selections v. Trump: CAFC Sets Expedited En Banc Review of Tariff Orders After Staying CIT’s Injunction

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    In V.O.S. Selections, Inc. v. Trump, the Federal Circuit has now stayed the Court of International Trade’s injunctions and agreed to hear the government’s appeal on an expedited basis before the full court. This appeal by the Trump Administration follows the CIT’s landmark ruling that certain Executive Orders imposing tariffs were unlawful and issued a…

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  • Mitek Systems, Inc. v. United Services Automobile Association: No Standing for Declaratory Non-Infringement Claims Based on Indirect Liability or Customer Indemnity

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    In a detailed and precedent-reinforcing opinion issued on June 12, 2025, the Federal Circuit in Mitek Systems, Inc. v. United Services Automobile Association, No. 23-1687, affirmed the dismissal of Mitek’s declaratory judgment action for lack of subject-matter jurisdiction. The court held that Mitek failed to establish a justiciable controversy under Article III and the Declaratory…

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  • United Services Automobile Association v. PNC Bank N.A.: Federal Circuit Invalidates Mobile Check Deposit Patent as Abstract and Non-Inventive

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    In United Services Automobile Association v. PNC Bank N.A., the Federal Circuit reversed a district court ruling that had upheld the patent eligibility of United Services Automobile Association’s (“USAA”) mobile check deposit patent, holding instead that the asserted claim of U.S. Patent No. 10,402,638 (“the ’638 patent”) was directed to an abstract idea and lacked…

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  • Agilent v. Synthego: Federal Circuit Clarifies Written Description and Motivation to Combine

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    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

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    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

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    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

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    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

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    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

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    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

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    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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