The Technology & Information Law Blog

Analysis by Charles Gideon Korrell

  • Federal Circuit Ruling on Crown Packaging v. Belvac: A Lesson in the On-Sale Bar

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    On December 10, 2024, the Federal Circuit issued a significant ruling in Crown Packaging Technology, Inc. v. Belvac Production Machinery, Inc., reversing a district court’s decision on patent validity and reinforcing the strength of the on-sale bar under pre-AIA 35 U.S.C. § 102(b). This case highlights the importance of commercial offers for sale and their…

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  • Galderma v. Lupin: CAFC Weighs In on ANDA Infringement and the Doctrine of Equivalents

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    The Federal Circuit recently affirmed a district court ruling in Galderma Laboratories, L.P. v. Lupin Inc., a patent dispute over the rosacea treatment Oracea®. The decision highlights key issues in Hatch-Waxman litigation, including claim construction, infringement analysis, and the doctrine of equivalents. Background: The Patents and ANDA Dispute Galderma Laboratories owns patents for Oracea®, medication…

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  • Cytiva v. JSR: Inherent Results Cannot Rescue an Otherwise Obvious Patent

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    In a significant decision for biotechnology and pharmaceutical patents, the Federal Circuit has affirmed-in-part and reversed-in-part the Patent Trial and Appeal Board’s (PTAB) findings in Cytiva BioProcess R&D AB v. JSR Corp.. The case centers around chromatography matrices and protein engineering, with the core dispute being whether certain patent claims were obvious and therefore unpatentable.…

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  • Federal Circuit Affirms Non-Infringement in Mirror Worlds v. Meta: Key Patent Law Takeaways

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    On December 4, 2024, the Federal Circuit issued its decision in Mirror Worlds Technologies, LLC v. Meta Platforms, Inc., upholding the district court’s grant of summary judgment in favor of Meta (formerly Facebook) on all claims of patent infringement. The case, involving patents related to time-ordered data streams, raised important issues in patent law, particularly…

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  • Citibank v. Mitchell: Trade Secret Use From Memory Can Be Misappropriation

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    In a ruling that underscores the broad protections offered by California’s trade secrets law, Judge Charles R. Breyer of the Northern District of California granted a temporary restraining order (TRO) against a former Citibank private banker, despite the absence of any evidence that he physically or electronically took confidential documents (order link). The court held…

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  • Ericsson v. Lenovo: The Federal Circuit Revisits SEP Licensing and Injunctions

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    In a major decision involving standard-essential patents (SEPs) and international licensing disputes, the Federal Circuit vacated a district court’s denial of an antisuit injunction requested by Lenovo against Ericsson. The case revolves around fair, reasonable, and non-discriminatory (FRAND) licensing commitments, the enforcement of foreign patent injunctions, and how U.S. courts handle international patent disputes. Background:…

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  • Federal Circuit Ruling in NexStep v. Comcast: Key Patent Law Takeaways

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    On October 24, 2024, the United States Court of Appeals for the Federal Circuit issued a significant decision in NexStep, Inc. v. Comcast Cable Communications, LLC, affirming the district court’s ruling of non-infringement on two patents owned by NexStep. The case raised important questions about claim construction, the doctrine of equivalents, and evidentiary requirements for…

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  • UTTO v. Metrotech: Claim Construction Can Begin at the Pleading Stage

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    The Federal Circuit issued its decision in UTTO Inc. v. Metrotech Corp., a case centered on patent infringement and state-law tort claims. This decision provides significant insights into claim construction, infringement analysis, and the role of economic torts in intellectual property disputes. Below, we explore the key patent law issues addressed by the court. Background…

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  • Court of Appeals Reverses Dismissal in AlexSam v. Aetna: Key Patent Law Issues Explained

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    The Federal Circuit’s recent decision in AlexSam, Inc. v. Aetna, Inc. (Case No. 22-2036) highlights critical issues in patent licensing, direct and indirect infringement, and pleading standards in patent litigation. The court vacated and remanded parts of the district court’s dismissal, finding that key errors had been made in assessing AlexSam’s claims against Aetna. Below,…

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  • Federal Circuit Revives False Advertising Claim Against Crocs: Key Patent Law Issues

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    The Federal Circuit recently issued a significant ruling in Crocs, Inc. v. Effervescent, Inc., reversing the District Court for the District of Colorado’s summary judgment in favor of Crocs, Inc. The ruling addresses key issues at the intersection of patent law and false advertising under the Lanham Act, providing a critical clarification on how misrepresentations…

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