Opinions

This morning the Federal Circuit released three precedential opinions. The first comes in a takings case appealed from the Court of Federal Claims. In it, the Federal Circuit reversed the Claims Court’s finding that the property interests at issue were easements. The second comes in patent case appealed from the Western District of Wisconsin. In it, the Federal Circuit reversed the district court’s construction of a specific term, vacated the district court’s grant of summary judgment with respect to one patent, and affirm the district court’s grant of summary judgment with respect to another patent. The third comes in a patent case appealed from the District of Delaware. In it, the Federal Circuit affirmed the district court’s finding of lack of eligibility. The Federal Circuit also released a nonprecedential opinion in a patent case appealed from Patent Trial and Appeal Board. Finally, the Federal Circuit released a nonprecedential order dismissing an appeal.

Behrens v. United States (Precedential)

Appellants are property owners seeking compensation for an alleged taking pursuant to the National Trails System Act (“Trails Act”), Pub. L. No. 90-543, 82 Stat. 919 (1968) (codified as amended at 16 U.S.C. §§ 1241–51). The issuance of a Notice of Interim Trail Use (“NITU”) allowing interim trail use and railbanking constitutes a Fifth Amendment taking if the railroad had been granted an easement, interim trail use and railbanking were beyond the scope of the easement, and the NITU caused a delay in termination of the easement. The Court of Federal Claims (“Claims Court”) found that the property interests at issue were easements, but that interim trail use was within the scope of the easements. We hold that the Claims Court erred in interpreting Missouri law and in concluding that interim trail use was within the scope of the easements. We also hold that railbanking is not within the scope of the easements. There being no causation dispute, the NITU issuance constituted a taking. We reverse and remand.

SSI Technologies, LLC v. Dongguan Zhengyang Electronic Mechanical Ltd. (Precedential)

Appellant SSI Technologies, LLC, (“SSI”) brought this action against appellee Dongguan Zhengyang Electronic Mechanical LTD (“DZEM”), alleging that DZEM infringes two of SSI’s patents. DZEM asserted counterclaims for invalidity of the asserted patents and for tortious interference with prospective business relations. The district court granted summary judgment to DZEM on the infringement claims and dismissed DZEM’s invalidity counterclaims. The court also granted summary judgment to SSI on the tortious interference counterclaim. We affirm in part, reverse in part, vacate in part, and remand.

Chromadex, Inc. v. Elysium Health, Inc. (Precedential)

ChromaDex, Inc. (“ChromaDex”) and the Trustees of Dartmouth College (“Dartmouth”) (collectively, “Appellants”) appeal the decision of the U.S. District Court for the District of Delaware granting Elysium Health, Inc.’s (“Elysium”) motion for summary judgment that the asserted claims of U.S. Patent No. 8,197,807 (“the ’807 patent”) are directed to unpatentable subject matter under 35 U.S.C. § 101. We affirm.

Softbellys, Inc. v. TY Inc. (Nonprecedential)

Softbelly’s, Inc. (“Softbelly’s”) appeals from a final written decision of the Patent Trial and Appeal Board (“Board”) in an inter partes review (“IPR”) determining all challenged claims of Softbelly’s U.S. Patent No. 6,195,831 (“the ’831 patent”) unpatentable. We affirm.

Dismissal