Opinions

This morning the Federal Circuit released related precedential and nonprecedential opinions addressing parallel appeals from judgments of a district court and the Patent Trial and Appeal Board related to the same patents. In the precedential opinion, the Federal Circuit vacates a district court’s judgment of willful infringement and remands with instructions to dismiss the case as moot given the Federal Circuit’s holding in the related nonprecedential opinion affirming final written decisions of the Patent Trial and Appeal Board finding all of the asserted claims invalid. The Federal Circuit also released another precedential opinion reversing a district court’s finding of lack of personal jurisdiction in another patent infringement dispute. Finally, the Federal Circuit released a second nonprecedential opinion, this one in a separate appeal from another final written decision of the Patent Trial and Appeal Board in an inter partes review proceeding. Here are the introductions to the opinions.

SnapRays v. Lighting Defense Group (Precedential)

SnapRays, d/b/a SnapPower (SnapPower) appeals a judgment of the United States District Court for the District of Utah dismissing its complaint for declaratory judgment of noninfringement against Lighting Defense Group (LDG) for lack of personal jurisdiction. Because we conclude LDG purposefully directed extra-judicial patent enforcement activities at SnapPower in Utah, we reverse and remand for further proceedings.

Packet Intelligence LLC v. Netscout Systems, Inc. (Precedential)

NetScout Systems, Inc. and NetScout Systems Texas, LLC (collectively, “NetScout”) appeal the amended final judgment entered by the U.S. District Court for the Eastern District of Texas (“Eastern District”), contending that the district court erred in granting enhanced damages for willful infringement and in setting the rate and effective date for an ongoing royalty. In view of the parallel appeals in which we have affirmed the final written decisions of the Patent Trial and Appeal Board (“Board”) finding all of the patent claims asserted by Packet Intelligence LLC (“Packet”) in this case invalid, we vacate the district court’s amended final judgment and remand with instructions to dismiss the case as moot.

Packet Intelligence, LLC v. Juniper Networks, Inc. (Nonprecedential)

Packet Intelligence LLC (“Packet”) appeals the final written decisions of the Patent Trial and Appeal Board (“Board”) in inter partes review (“IPR”) proceedings finding certain claims of its U.S. Patent Nos. 6,665,725 (“’725 patent”), 6,771,646 (“’646 patent”), 6,839,751 (“’751 patent”), and 6,954,789 (“’789 patent”) are unpatentable as obvious. Juniper Networks, Inc. and Palo Alto Networks, Inc., (collectively, “Juniper”) cross-appeal the Board’s final written decisions finding claim 3 of the ’646 patent and claim 34 of the ’789 patent are not unpatentable as obvious. We affirm in all respects.

Kirsch Research & Development, LLC v. GAF Materials LLC (Nonprecedential)

Patent owner Kirsch Research and Development, LLC (“Kirsch”) appeals a final written decision of the U.S. Patent Trial and Appeal Board (“Board”) in an inter partes review (“IPR”) that found all claims of its U.S. Patent No. 6,308,482 (“’482 patent”) unpatentable over prior art. We affirm.