This morning, the Federal Circuit released a precedential opinion in a patent case that reverses a district court and finds all asserted claims invalid for lack of eligibility. The Federal Circuit also released two nonprecedential opinions, one in another patent case appealed from another district court and another in a pro se case appealed from the Court of Veterans Appeals. The Federal Circuit also released a nonprecedential order transferring a case, an errata, and a Rule 36 summary affirmance. Here are the introductions to the opinions and links to the transfer, errata, and summary affirmance.
GoTV Streaming, LLC v. Netflix, Inc. (Precedential)
GoTV Streaming, LLC owns the three related U.S. Patent Nos. 8,478,245, 8,989,715, and 8,103,865 at issue here. Those patents claim methods and systems involving a server that receives a request for content from a wireless device, delivers the requested content to the device for the device to render (i.e., for visual content, to place on the device’s screen), and has tailored the specifications for the to-be-rendered content to the screen size or other capabilities of the requester’s device. GoTV sued Netflix, Inc., alleging that Netflix directly infringed and induced infringement of all three patents. We have before us GoTV’s appeal and Netflix’s cross-appeal from a final judgment granting some relief to GoTV.
Before trial, the district court dismissed GoTV’s claims of induced infringement and rejected Netflix’s challenge to the asserted claims as ineligible for patenting under 35 U.S.C. § 101. The court, when construing some claim terms, held all asserted claims of the ’865 patent invalid for indefiniteness, and it also denied GoTV’s request to exclude certain of Netflix’s proposed damages evidence. A jury trial was held on one claim from each of the ’245 and ’715 patents, after which the jury found that Netflix infringed only the ’715 patent and awarded GoTV $2.5 million in damages, representing a life-of-patent lump sum starting from the filing of this action (GoTV having disclaimed pre-complaint damages). The district court denied several of GoTV’s post-trial motions, including a request for retrial of damages because of allegedly improper Netflix damages evidence and a request for prejudgment interest from before the complaint’s filing. The court entered final judgment, from which GoTV appeals and Netflix cross-appeals.
We hold, on Netflix’s cross-appeal, that the claims at issue are ineligible for patenting under § 101. In considering the claims’ meaning for purposes of that issue, we reverse the district court’s holding that an element of the ’865 patent claims was indefinite, and we adopt GoTV’s construction of that element. Our ineligibility conclusion requires reversal of the district court’s judgment and entry of judgment in the case for Netflix. We therefore do not rule definitively on GoTV’s arguments on appeal other than its challenge to the district court’s indefiniteness ruling. But because GoTV has raised substantial arguments against the district court’s no-inducement ruling and allowance of certain damages evidence presented by Netflix, we expressly vacate those rulings of the district court.
Abiomed Inc. v. Maquet Cardiovascular LLC (Nonprecedential)
Maquet Cardiovascular LLC (“Maquet”) appeals from a final judgment of the United States District Court for the District of Massachusetts, ordering that Abiomed Inc., Abiomed Europe GmbH, and Abiomed R&D, Inc. (collectively, “Abiomed”) have not infringed any claim of U.S. Patent Nos. 7,022,100; 8,888,728; 9,327,068; 9,545,468; 9,561,314; and 9,597,437 (collectively, the “Asserted Patents”). J.A. 1–2. For the reasons discussed below, we affirm-in-part, vacate-in-part, and remand.
Moore v. Collins (Nonprecedential)
Jeffrey A. Moore appeals the May 22, 2025 memorandum decision of the United States Court of Appeals for Veterans Claims (“Veterans Court”) in Moore v. Collins, No. 24-2507, S. App. 1. In that decision, the Veterans Court affirmed the March 29, 2024 order of the Board of Veterans’ Appeals (“Board”) that denied Mr. Moore’s claims for Department of Veterans Affairs (“VA”) disability benefits and total disability based on individual unemployability (“TDIU”). S. App. 12. For the reasons set forth below, we dismiss Mr. Moore’s appeal for lack of jurisdiction.