This morning the Federal Circuit issued one precedential opinion in a patent case addressing ineligibility and a motion for leave to file an amended complaint and one nonprecedential opinion in a takings case appealed from the Court of Federal Claims. Here are the introductions to the opinions.
Simio, LLC v. Flexsim Software Products, Inc. (Precedential)
Simio, LLC (“Simio”) sued FlexSim Software Products, Inc. (“FlexSim”) in the United States District Court for the District of Utah for infringing U.S. Patent No. 8,156,468 (“the ’468 patent”). The district court held the asserted claims of the ’468 patent ineligible for patenting under 35 U.S.C. § 101 and, as a result, dismissed the action because Simio’s complaint failed to state a claim upon which relief could be granted. Simio then moved for leave to file an amended complaint, which the district court denied.
Simio appeals the dismissal and the denial of its motion for leave to amend. We affirm.
Taylor & Sons, Inc. v. United States (Nonprecedential)
Before mid-2009, the plaintiffs in these cases were automobile dealers operating as franchisees of Chrysler LLC. In that year, Chrysler filed a petition for reorganization in bankruptcy, and it rejected the franchise agreements in the bankruptcy proceeding under 11 U.S.C. § 365. Plaintiffs sued the United States in the Court of Federal Claims, alleging that the government played a role in Chrysler’s rejection of the franchise agreements that constituted a taking of their property, requiring just compensation under the Takings Clause of the Fifth Amendment to the United States Constitution. In 2014, agreeing with the Claims Court, we allowed the case to proceed beyond the pleading stage. A & D Auto Sales, Inc. v. United States, 748 F.3d 1142 (Fed. Cir. 2014). On remand, the Claims Court, after a full trial, rejected the claims on two grounds—first, that the government’s actions did not amount to coercion of Chrysler’s decision to reject the franchise agreements and, second, that plaintiffs did not prove that the franchise agreements would have had value but for those actions. Colonial Chevrolet Co, Inc. v. United States, 145 Fed. Cl. 243 (2019) (Trial Opinion). On plaintiffs’ appeal, we now affirm on the latter ground and do not address the former.