This morning the Federal Circuit released a precedential opinion in a patent case appealed from the Central District of California. In it, the Federal Circuit affirms the district court’s claim construction, dismissal of a claim, and grant of summary judgment that trade dress is invalid, vacates a denial of summary judgment on an inequitable conduct defense, reverses a grant of summary judgment of invalidity, and remands the case. Late yesterday, the Federal Circuit also released two nonprecedential orders dismissing appeals. Here is the introduction to the opinion and links to the dismissals.
Mosaic Brands, Inc. v. Ridge Wallet LLC (Precedential)
This is an intellectual property case about wallets. Mosaic Brands, Inc. d/b/a Storus (“Mosaic”) and Ridge Wallet LLC (“Ridge”) make similar money-clip wallets. Each company accuses the other of patent infringement. Mosaic asserts that Ridge infringes its U.S. Patent No. 7,334,616 (“’616 patent”) as well as Mosaic’s trade dress. Ridge denies these allegations and further contends that Mosaic infringes its U.S. Patent No. 10,791,808 (“’808 patent”).
Following claim construction, the parties stipulated that Mosaic cannot prove infringement of its ’616 patent. The District Court then granted summary judgment of invalidity of Ridge’s ’808 patent, based on anticipation, and denied Mosaic’s motion for summary judgment that Ridge had obtained its ’808 patent through inequitable conduct. The District Court also granted summary judgment to Ridge on Mosaic’s trade dress claim, finding the trade dress invalid on multiple grounds. Mosaic and Ridge both appealed.
As explained below, we affirm the District Court’s claim construction and, accordingly, its dismissal of Mosaic’s claim that Ridge infringes the ’616 patent. However, because we find genuine disputes of material fact as to whether Mosaic’s Smart Money Clip II product is prior art to Ridge’s patent, we reverse the grant of summary judgment of invalidity of Ridge’s ’808 patent. We also vacate the District Court’s denial of summary judgment on Mosaic’s inequitable conduct defense. Finally, we affirm the District Court’s grant of summary judgment that Mosaic’s trade dress is invalid.