This morning, the Federal Circuit released two precedential opinions, one in a patent case appealed from the Western District of Texas and one in a trade case appealed from the Court of International Trade. The Federal Circuit also released a nonprecedential opinion in a patent case appealed from the Middle District of Florida. Here are the introductions to the opinions.
Jiaxing Super Lighting Electric Appliance, Co. v. CH Lighting Technology Co. (Precedential)
Jiaxing Super Lighting Electric Appliance Co., Ltd. and its North American affiliate Obert, Inc. (collectively, “Super Lighting”) brought suit against CH Lighting Technology Co., Ltd., Elliott Electric Supply, Inc., and Shaoxing Ruising Lighting Co., Ltd. (collectively, “CH Lighting”) for infringement of U.S. Patent Nos. 10,295,125 (the “’125 patent”), 10,352,540 (the “’540 patent”), and 9,939,140 (the “’140 patent”). Before trial, CH Lighting conceded infringement of the ’125 and ’540 patents. At trial, the district court granted Super Lighting’s motions to exclude evidence relating to the validity of the asserted claims of the ’125 and ’540 patents and subsequently granted Super Lighting’s motion for judgment as a matter of law (“JMOL”) that the ’125 and ’540 patents were not invalid on the ground of an on-sale bar. A jury found the ’140 patent infringed and not invalid and awarded damages for infringement of claims of the three patents. CH Lighting appeals.
We conclude as follows. First, the district court erred in granting JMOL that the ’125 and ’540 patents were not invalid because it erroneously prevented CH Lighting from presenting evidence of their invalidity; the district court was required to hold a new trial as to the invalidity of the ’125 and ’540 patents. Second, with respect to the ’140 patent, substantial evidence supports the jury’s verdicts of infringement and no invalidity. Third, the district court should assess the reliability of Ms. Kindler’s testimony consistent with this court’s recent en banc decision in EcoFactor and under Rule 702 of the Federal Rules of Evidence. Accordingly, a new trial is required as to the validity of the ’125 and ’540 patents and as to damages for infringement of all three patents. We accordingly affirm-in-part, reverse-in-part, vacate-in-part, and remand for further proceedings consistent with this opinion.
Jilin Forest Industry Jinqiao Flooring Group Co. v. United States (Precedential)
The government appeals the decision of the Court of International Trade (“CIT”), which held that it was unlawful for the Department of Commerce (“Commerce”) to assign a non-market economy (“NME”) country-wide antidumping duty rate to Jilin Forest Industry Jinqiao Flooring Group Co. (“Jilin”). We reverse.
WhereverTV, Inc. v. Comcast Cable Communications, LLC (Nonprecedential)
WhereverTV, Inc. sued Comcast Cable Communications, LLC for patent infringement in the United States District Court for the Middle District of Florida, and the case proceeded to a jury trial on infringement of claim 1 of U.S. Patent No. 8,656,431. After the close of evidence but prior to a jury verdict, however, the district court granted Comcast’s motion for judgment of noninfringement as a matter of law under Rule 50(a) of the Federal Rules of Civil Procedure. WhereverTV appeals the district court’s JMOL, alleging that it rests on erroneous constructions of two terms in claim 1. As an alternative ground for affirmance, Comcast argues that it is entitled to JMOL based on what it asserts is the correct interpretation of a separate claim term, and it cross-appeals the district court’s determination that claim 1 is not indefinite under 35 U.S.C. § 112. Because we agree with WhereverTV that the district court erred in its claim construction, and we reject Comcast’s alternative grounds for affirmance as well as its argument that claim 1 is indefinite, we vacate the district court’s JMOL of noninfringement and remand for proceedings consistent with this opinion.