Late yesterday, the Federal Circuit released a nonprecedential order dismissing an appeal. This morning, the court released one precedential opinion and two nonprecedential opinions. The precedential opinion comes in a patent infringement case, and the key claim at issue in the dispute was a means-plus-function limitation. One of the nonprecedential opinions also comes in another patent infringement case; the other nonprecedential opinion comes in an appeal of a decision of the Merit Systems Protection Board. Here are introductions to the opinions and links to the dismissal.
Genuine Enabling Technology LLC v. Sony Group Corp. (Precedential)
Genuine Enabling Technology LLC (GET) appeals the U.S. District Court for the District of Delaware’s grant of summary judgment of noninfringement in favor of Sony Group Corporation & Sony Interactive Entertainment LLC (collectively, Sony). Genuine Enabling Tech. LLC v. Sony Corp., No. 17-CV-135, 2024 WL 1255513, at *1 (D. Del. Mar. 25, 2024) (Decision). The district court determined that GET raised no genuine issue of material fact as to whether Sony’s Accused Products—PlayStation 3 and 4 controllers and consoles—infringe claims 10, 14, 16–18, and 21–23 of U.S. Patent No. 6,219,730 (’730 patent). Id. GET also appeals the district court’s exclusion of testimony from its expert, Dr. Fernald. Genuine Enabling Tech. LLC v. Sony Corp., No. 17-CV-135, 2022 WL 17325656, at *8 (D. Del. Nov. 28, 2022) (Daubert Order). The key claim limitation in this dispute is a means-plus-function limitation— “encoding means for synchronizing” two input data streams—and the specification describes FIG. 4A’s logic block 34, a logic design circuit containing a multitude of elements, as the corresponding structure for performing the synchronizing function. Because GET and its expert failed to account for many of the elements in block 34 in their infringement analysis, we agree with the district court that GET presented a deficient infringement case as to this limitation and we thus affirm.
Corcept Therapeutics, Inc. v. Teva Pharmaceuticals USA, Inc. (Nonprecedential)
Corcept Therapeutics, Inc. (Corcept) appeals a decision from the United States District Court for the District of New Jersey finding no infringement of U.S. Patent Nos. 10,195,214 and 10,842,800. For the following reasons, we affirm.
Ryan v. Department of Veterans Affairs (Nonprecedential)
In 2022, the Veterans Health Administration of the Department of Veterans Affairs (agency) terminated the employment of John Ryan, a clinical social worker, for careless performance and inappropriate conduct. Both charges related to Mr. Ryan’s actions or inaction involving a veteran under his care who was identified as presenting a high risk for suicide. The Merit Systems Protection Board sustained Mr. Ryan’s removal. See Ryan v. Department of Veterans Affairs, No. CH-0752-22-0147-I-1, 2024 WL 1232093 (M.S.P.B. Mar. 21, 2024) (Final Board Decision); J.A. 1–7. We now affirm the Board’s decision.