This morning, the Federal Circuit released one precedential opinion and four nonprecedential opinions. The precedential opinion comes in a patent case appealed from the Eastern District of Texas. One nonprecedential opinion comes in a patent case appealed from the Patent Trial and Appeal Board, one comes in a trade case appealed from the Court of International Trade, one comes in patent case appealed from the District of Delaware, and the last opinion comes in response to a petition for review of a decision from the Merit Systems Protection Board. Here are the introductions to the opinions.
Ollnova Technologies Ltd. v. ecobee Technologies ULC (Precedential)
Ollnova Technologies Ltd. (Ollnova) sued ecobee Technologies ULC d/b/a ecobee (ecobee) for patent infringement in the United States District Court for the Eastern District of Texas. Ollnova asserted U.S. Patent Nos. 7,860,495 (’495 patent), 8,264,371 (’371 patent), 7,746,887 (’887 patent), and 8,224,282 (’282 patent) (collectively, the Asserted Patents). The Asserted Patents are directed to improvements in wireless communications used in building automation systems. Ollnova contends that ecobee’s smart thermostat products infringe the Asserted Patents.
The jury returned a verdict that (i) found ecobee infringed at least one of the Asserted Patents (but without identifying which patent or patents); (ii) found the ’495 patent’s asserted claims were not directed only to “well-understood, routine, and conventional” technology; (iii) found the ’282 patent’s asserted claims were invalid; and (iv) awarded Ollnova lump sum damages of $11.5 million covering the life of the patents.
ecobee appeals the district court’s (1) denial of ecobee’s motion for a new trial based on the allegedly flawed jury instruction and verdict form as to ecobee’s challenge to the ’495 patent’s validity under 35 U.S.C. § 101; (2) denial of ecobee’s motion for judgment as a matter of law that the ’495 patent’s asserted claims are invalid under 35 U.S.C. § 101; (3) denial of ecobee’s motions to dismiss under 35 U.S.C. § 101 for the ’887 and ’371 patents; (4) denial of ecobee’s motion for judgment as a matter of law concerning non-infringement of the ’371 patent; (5) denial of ecobee’s motion for a new trial due to the verdict form’s inclusion of a single question covering infringement for all the Asserted Patents; and (6) denial of ecobee’s Daubert motions to exclude expert testimony related to damages and its marking defense. Ollnova appeals the district court’s order that prejudgment interest is limited to the time period allowed under 35 U.S.C. § 286.
For the reasons below, we vacate the infringement and damages judgments and remand for proceedings consistent with this opinion, including a new trial on infringement and damages. We vacate and remand for further proceedings under Alice step two of the 35 U.S.C. § 101 analysis as to the ’495 patent. We affirm the district court’s determinations that the asserted claims of the ’887 and ’371 patents are not directed to an abstract idea under 35 U.S.C. § 101. We also affirm the district court’s denial of ecobee’s motion for judgment as a matter of law concerning non-infringement of the ’371 patent. Because we vacate the damages judgment, we do not reach ecobee’s remaining arguments regarding its Daubert motions on damages and marking or Ollnova’s arguments regarding prejudgment interest.
Life Spine, Inc. v. Globus Medical, Inc. (Nonprecedential)
Life Spine, Inc. (“Life Spine”) appeals from a Final Written Decision of the Patent Trial and Appeal Board (“Board”) in an inter partes review that held claims 10-14 of Globus Medical, Inc.’s (“Globus”) U.S. Patent No. 8,845,731 (“’731 patent”) not unpatentable.1 Life Spine’s challenge rests entirely on its disagreement with the Board’s construction of the claim term “complementary with one another.” We agree with Life Spine’s proposed construction. Since it is undisputed that the challenged claims are obvious under this construction, we reverse the Board.
Chadan Steel Ltd. v. United States (Nonprecedential)
Chandan Steel Limited (“Chandan”) appeals from a final decision of the Court of International Trade (“Trade Court”) upholding an antidumping order on stainless steel flanges from India by the International Trade Administration, U.S. Department of Commerce (“Commerce”). See Kisaan Die Tech Priv. Ltd. v. United States, 665 F. Supp. 3d 1364 (Ct. Int’l Trade 2023) (“Decision”). For the reasons below, we affirm.
Arendi S.A.R.L. v. Oath Holdings Inc. (Nonprecedential)
Arendi S.A.R.L. (“Arendi”) appeals from final judgments of the United States District Court for the District of Delaware holding that Google LLC (“Google”) and Oath Holdings Inc. (“Oath”) do not infringe the asserted claims of U.S. Patent No. 7,917,843 (the “’843 patent”) and that those claims are invalid as both anticipated and obvious over the prior art, and from the court’s grant of judgment on the pleadings under Federal Rule of Civil Procedure 12(c) holding that the asserted claims of U.S. Patents No. 7,496,854 (the “’854 patent”), No. 7,921,356 (the “’356 patent”), and No. 8,306,993 (the “’993 patent”) are directed to patent-ineligible subject matter under 35 U.S.C. § 101. See Arendi S.A.R.L. v. Google LLC, No. 13-cv-919, Dkt. No. 616 (D. Del. Feb. 2, 2024) (“Final Judgment”); Arendi S.A.R.L. v. Google LLC, No. 13-cv-919, Dkt. No. 625 (D. Del. Jan. 14, 2026) (“Amended Final Judgment”); Arendi S.A.R.L. v. Google LLC, No. 13-cv-919, Dkt. No. 201 (D. Del. Jan. 2, 2020) (“Rule 12(c) Order”). Google argues as an alternative ground for affirmance that the ’843 patent is also directed to patent ineligible subject matter under section 101. For the following reasons, we affirm and hold that the asserted claims of each of the four patents claim patent ineligible subject matter under section 101. Accordingly, we do not reach the other issues.
Shandler v. Office of Personnel Management (Nonprecedential)
Joshua D. Shandler petitions for review of a final decision of the Merit Systems Protection Board (“Board”) affirming Office of Personnel Management’s denial of disability retirement annuity benefits. For the following reasons, we dismiss Mr. Shandler’s petition to review as untimely.