This morning the Federal Circuit issued one precedential opinion in a patent case, one precedential opinion in an employment case, and one nonprecedential opinion in a patent case. Here are the introductions to the opinions.
Network-1 Technologies, Inc. v. Hewlett-Packard Company (Precedential)
Network-1 Technologies, Inc. (“Network-1”) appeals a final judgment of the United States District Court for the Eastern District of Texas. Network-1 sued Hewlett-Packard (“HP”), alleging infringement of U.S. Patent No. 6,218,930 (“the ’930 patent”). HP argued in response that the ’930 patent is invalid, and that HP did not infringe. The jury found the patent not infringed and invalid. Following post-trial motions, the district court denied Network-1’s request for a new trial on infringement but granted Network-1’s motion for judgment as a matter of law (“JMOL”) on validity.
Network-1 appeals the district court’s final judgment that HP does not infringe the ’930 patent, arguing the district court erred in its claim construction. HP cross-appeals the district court’s determination that HP was estopped from raising certain validity challenges under 35 U.S.C. § 315(e)(2) based on HP’s joinder to an inter partes review (“IPR”) before the Patent Trial and Appeal Board (“Board”). On cross-appeal, HP also argues that Network-1 improperly broadened claim 6 of the ’930 patent during reexamination.
For the reasons explained below, we affirm-in-part, reverse-in-part, vacate, and remand. Specifically, as to Network-1’s appeal, we affirm-in-part and reverse-in-part the district court’s claim construction and remand to the district court. As to HP’s cross-appeal, we vacate the district court’s JMOL on validity and remand. And finally, we affirm the district court’s decision with respect to improper claim broadening.
Shea v. United States (Precedential)
John Shea appeals the decision of the United States Court of Federal Claims denying him liquidated damages following his employer’s erroneous classification of his position as exempt from the overtime provisions of the Fair Labor Standards Act. Because the Court of Federal Claims did not err, we affirm the decision.
John Bean Technologies Corp. v. Morris & Associates, Inc. (Nonprecedential)
John Bean Technologies Corp. brought this action against Morris & Associates, a rival in the business of supplying equipment to poultry processors. John Bean asserts that Morris engaged in false patent marking, false advertising, deceptive trade practices, and unfair competition with respect to Morris’s IntraGrill auger chiller and Morris’s COPE (Continuous Online Pathogen Eliminator) decontamination tanks. The key allegation of the complaint is the asserted falsity of Morris’s representations, in product markings or advertisements, that the Morris products at issue are covered by three Morris patents, U.S. Patent Nos. 6,308,529, 7,470,173, and 7,588,489.
The district court granted summary judgment to Morris on John Bean’s claims involving Morris’s auger chiller on the ground that there was insufficient evidence to allow a reasonable factfinder to find that John Bean had been competitively injured by the challenged conduct. We affirm that ruling. The district court also granted summary judgment rejecting John Bean’s claims involving Morris’s decontamination tanks. We affirm that ruling as well.