The Technology & Information Law Blog

Analysis by Charles Gideon Korrell

  • In re PT Medisafe Technologies: Federal Circuit Affirms Color Mark as Generic

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    In In re PT Medisafe Technologies, No. 23-1573 (Fed. Cir. Apr. 29, 2025), the Federal Circuit affirmed the PTAB’s refusal to register a dark green color mark for medical examination gloves, concluding that the color was generic and not eligible for trademark protection. Background Medisafe, a manufacturer and distributor of medical gloves, sought to register…

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  • Qualcomm v. Apple: Express Reliance on Applicant Admitted Prior Art Bars IPR Ground

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    In Qualcomm Inc. v. Apple Inc., Nos. 2023-1208, -1209 (Fed. Cir. Apr. 23, 2025), the Federal Circuit reversed the Patent Trial and Appeal Board’s (PTAB) post-remand decision, holding that the Board erred in allowing Apple’s inter partes review (IPR) ground to proceed based on a misinterpretation of 35 U.S.C. § 311(b). The ruling clarifies the…

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  • Marmen Inc. v. United States — Federal Circuit Rejects Commerce’s Use of Cohen’s d Test in Dumping Margin Calculation

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    In Marmen Inc. v. United States, No. 23-1877 (Fed. Cir. Apr. 22, 2025), the Federal Circuit vacated and remanded the Department of Commerce’s antidumping duty (AD) determination for utility-scale wind towers from Canada. The decision raises important questions about Commerce’s use of statistical methods in calculating dumping margins, and it reinforces key limitations previously addressed…

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  • Dongkuk S&C Co., Ltd. v. United States: Federal Circuit Backs Commerce’s Methodology for Cost Adjustments and Surrogate Profit Selection in Antidumping Review

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    In Dongkuk S&C Co., Ltd. v. United States, No. 23-1419 (Fed. Cir. Apr. 21, 2025), the Federal Circuit affirmed the U.S. Department of Commerce’s determinations in its antidumping investigation of utility-scale wind towers from South Korea. The decision clarifies Commerce’s discretion in adjusting reported production costs and selecting surrogate data when calculating constructed value under…

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  • Target Corporation v. United States: Federal Circuit Reaffirms Strict Finality in Customs Liquidation Errors

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    In Target Corp. v. United States, No. 2023-2274 (Fed. Cir. Apr. 21, 2025), the Federal Circuit reversed the Court of International Trade’s (CIT) dismissal of Target’s challenge to the reliquidation of antidumping entries, holding that the CIT improperly bypassed the statutory finality rules governing Customs’ liquidations. This decision reaffirms the holding in Cemex, S.A. v.…

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  • Recentive Analytics, Inc. v. Fox Corp.: Applying Generic Machine Learning to a New Environment Is Not Enough for Patent Eligibility

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    In Recentive Analytics, Inc. v. Fox Corp., No. 23-2437 (Fed. Cir. Apr. 18, 2025), the Federal Circuit affirmed the dismissal of a patent infringement suit on § 101 grounds, holding that Recentive’s asserted patents were directed to ineligible subject matter. The court concluded that the patents merely applied well-known machine learning techniques to the new…

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  • Sage Products, LLC v. Stewart: “Sterile” Label in UK Document Found to Anticipate U.S. “Sterilized” Patent Claims

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    In Sage Products, LLC v. Stewart, No. 2023-1603 (Fed. Cir. Apr. 15, 2025), the Federal Circuit affirmed the Patent Trial and Appeal Board’s (PTAB) finding that all challenged claims of Sage’s U.S. Patent Nos. 10,398,642 and 10,688,067 were unpatentable due to anticipation and obviousness. The ruling centered on whether a UK public assessment report (PAR)…

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  • Heritage Alliance v. American Policy Roundtable: Descriptive Marks Without Acquired Distinctiveness Can’t Block Later Applications

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    In Heritage Alliance v. American Policy Roundtable, No. 24-1155 (Fed. Cir. Apr. 9, 2025), the Federal Circuit affirmed the TTAB’s refusal to block registration of “iVoters” and “iVoters.com” despite evidence of earlier use of “iVoterGuide” and “iVoterGuide.com” by the challenger. The court agreed with the Board that Heritage’s marks were highly descriptive and had not…

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  • Azurity Pharmaceuticals v. Alkem Labs: Prosecution Disclaimer and “Consisting Of” Language Bar Infringement Finding

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    In Azurity Pharmaceuticals, Inc. v. Alkem Laboratories Ltd., No. 23-1977 (Fed. Cir. Apr. 8, 2025), the Federal Circuit affirmed the District of Delaware’s ruling that Alkem’s Abbreviated New Drug Application (ANDA) product did not infringe Azurity’s U.S. Patent No. 10,959,948 (“’948 patent”) due to a clear and unmistakable prosecution disclaimer of propylene glycol. Background Azurity’s…

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  • OSRAM v. Renesas Electronics: When Reverse Engineering Ends Trade Secret Protection

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    In AMS-OSRAM USA Inc. v. Renesas Electronics America, Inc., the Federal Circuit clarified key principles governing trade secret damages under Texas law, including how “head start” periods are calculated and when exemplary damages may be awarded in conjunction with equitable remedies. The decision also affirms that parallel contract damages are permissible where tied to non-overlapping…

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