This morning, the Federal Circuit released one precedential opinion and one nonprecedential opinion. The precedential opinion comes in a takings case on appeal from the Court of Federal Claims, while the nonprecedential opinion comes in a patent case on appeal from the District of Delaware. Here are the introductions to the opinions.
United Water Conservation Dist. v. United States (Precedential)
United Water Conservation District (“United”) appeals from a decision of the U.S. Court of Federal Claims (“the Claims Court”) dismissing its complaint for lack of subject matter jurisdiction. United Water Conservation Dist. v. United States, 164 Fed. Cl. 79 (2023) (“United Decision”).
United’s suit against the United States (“the government”) seeks just compensation for an alleged taking under the Fifth Amendment of the U.S. Constitution. The Claims Court dismissed United’s complaint because it determined that United’s claim should be evaluated as a regulatory taking and, because United had yet to exhaust its administrative remedies, its claim was “not yet viable for adjudication.” United Decision, at 91. For the following reasons, we affirm.
Express Mobile, Inc. v. GoDaddy.com, LLC (Nonprecedential)
Express Mobile, Inc. owns five patents at issue here. The first two are U.S. Patent No. 6,546,397 and its descendant No. 7,594,168 (the ’397 patent family), which describe and claim systems and methods for building websites. The other three are U.S. Patent No. 9,063,755 and its descendants Nos. 9,471,287 and 9,928,044 (the ’755 patent family), which describe and claim systems and methods for displaying website information, integrating widgets, and programming, especially on mobile devices.
In 2019, Express sued GoDaddy.com, LLC in district court, alleging infringement of those patents. The district court construed a claim phrase “runtime engine” in the ’397 family to require that it perform the function of “read[ing] information from the database” (to obtain material for building a website). Based on that construction, the district court granted GoDaddy summary judgment of noninfringement. Asserted claims of the ’755 family went to trial, and the jury found noninfringement. The district court denied Express’s requests for judgment as a matter of law (JMOL) or a new trial.
On Express’s appeal, we reverse the district court’s construction of the claim phrase “runtime engine” and vacate the summary judgment of noninfringement of the ’397 family’s claims. We affirm the district court’s denial of post-judgment relief from the jury’s verdict of noninfringement for the ’755 family. We remand the case for further proceedings regarding the ’397 family.