This morning, the Federal Circuit released five nonprecedential opinions. All come in patent cases. Two are appeals from district courts, two are appeals from the Patent Trial and Appeal Board, and one is an appeal from the International Trade Commission. Here are the introductions to the opinions.
Network-1 Technologies, Inc. v. Google LLC (Nonprecedential)
Network-1 Technologies, Inc. (“Network-1”) filed suit in the United States District Court for the Southern District of New York, asserting that two separate versions of Google LLC and YouTube, LLC’s (collectively, “Google”) Content ID system infringed several claims of its U.S. Patents 8,010,988 (“the ’988 patent”), 8,205,237 (“the ’237 patent”), 8,904,464 (“the ’464 patent”) (collectively, “the asserted patents”). Network-1 Techs., Inc. v. Google LLC, No. 14-cv-PGG-02396, 2024 WL 1814296 (S.D.N.Y. Apr. 24, 2024) (“Decision”). The district court issued a combined claim construction and summary judgment decision. Id. The court first determined that the asserted claims of the ’988 and ’464 patents are invalid as indefinite. Id. at *1. It then determined that neither version of Google’s Content ID system infringed the asserted claims of the ’237 patent as a matter of law and thus Google was entitled to summary judgment of noninfringement as to that patent. Id.
Because a genuine issue of material fact exists as to whether one version of Content ID infringes the ’237 patent, we reverse and remand as to that issue. We affirm the district court’s conclusion of invalidity of the ’988 and ’464 patents for indefiniteness and grant of summary judgment of noninfringement of the ’237 patent as to the other version of Content ID.
NantWorks, LLC v. Niantic, Inc. (Nonprecedential)
NantWorks, LLC and Nant Holdings IP, LLC (collectively, “NantWorks”) appeal decisions from the United States District Court for the Northern District of California. The district court granted Niantic, Inc.’s (“Niantic”) motion for judgment on the pleadings that claims 7, 14, 16, 19, 26, and 31 of U.S. Patent No. 10,664,518 are invalid under 35 U.S.C. § 101. NantWorks, LLC v. Niantic, Inc., No. 20-CV-06262-LB, 2023 WL 187490, at *1, *3–8 (N.D. Cal. Jan. 13, 2023) (“’518 Decision”). The district court also granted Niantic’s motion for summary judgment that claims 7, 22, 23, and 25 of U.S. Patent No. 10,403,051 are invalid under 35 U.S.C. § 101. NantWorks, LLC v. Niantic, Inc., No. 20-CV-06262-LB, 2024 WL 3363568, at *1–7 (N.D. Cal. July 9, 2024) (“’051 Decision”). For the following reasons, we affirm.
Slingshot Printing LLC v. Canon U.S.A., Inc. (Nonprecedential)
Slingshot Printing LLC (“Slingshot”) appeals from a final written decision of the Patent Trial and Appeal Board (“Board”) determining that claims 1–5 and 8 of U.S. Patent No. 7,195,341 (“the ’341 patent”) are unpatentable. For the reasons below, we affirm.
Centripetal Networks, LLC v. Keysight Technologies, Inc. (Nonprecedential)
Based on a petition filed by Keysight Technologies, Inc. (“Keysight”), the United States Patent and Trademark Office’s Patent Trial and Appeal Board (“the Board”) instituted inter partes review of claims 1–20 of U.S. Patent No. 10,193,917 (“the ’917 Patent”). The Board found claims 1–3, 5–13, and 15–20 unpatentable for obviousness. J.A. 50. The Board found claims 4 and 14 not unpatentable for obviousness. J.A. 50. Centripetal Networks, LLC (“Centripetal”), appeals the Board’s obviousness determinations as to claims 1–3, 5–13, and 15–20, and Keysight cross-appeals the Board’s non-obviousness determination as to claims 4 and 14. We have jurisdiction under 28 U.S.C. § 1295(a)(4)(A). We affirm as to claims 1– 3, 5–13, and 15–20 and we reverse as to claims 4 and 14.
Centripetal Networks, LLC v. International Trade Commission (Nonprecedential)
Based on a Complaint filed by Centripetal Networks, LLC (“Centripetal”), alleging that Keysight Technologies, Inc. (“Keysight”) violated 19 U.S.C. § 1337 (“Section 337”) in the importation and sale of articles that infringe certain claims of U.S. Patent Nos. 9,264,370 (“the ’370 Patent”), 10,193,917 (“the ’917 Patent), and 10,284,526 (“the ’526 Patent”), the U.S. International Trade Commission (“the Commission”) instituted investigation No. 337-TA-1314. J.A. 36225. On August 8, 2023, the administrative law judge issued a final initial determination (“Final ID”), finding no violation of Section 337 as to any asserted patent claim. J.A. 5, J.A. 286–87. Subsequently, the Commission affirmed the Final ID and terminated the investigation. J.A. 1. Centripetal appeals the Commission’s finding of no violation, with respect to the ’370 and ’917 Patents. We have jurisdiction under 28 U.S.C. § 1295(a)(6). We affirm.