Opinions

This morning, the Federal Circuit released five precedential opinions and one nonprecedential opinion. In the first two precedential opinions, the court affirmed judgments of the Central District of California and District of Delaware in patent cases. In the third precedential opinion, the Federal Circuit affirmed in part and reversed in part a judgment of the District of Delaware in another patent case. In the fourth precedential opinion, the Federal Circuit reversed, vacated, and remanded a judgment of the Northern District of Georgia in still another patent case. In the fifth precedential opinion, the Federal Circuit affirmed a judgment of the Court of International Trade. In the nonprecedential opinion, the Federal Circuit affirmed a judgment of the Patent Trial and Appeal Board. Here are the introductions to the opinions.

Sanderling Management Ltd. v. Snap Inc. (Precedential)

Sanderling Management Ltd. (“Sanderling”) appeals from the district court’s dismissal of Sanderling’s patent infringement suit against Snap Inc. (“Snap”) due to the asserted claims’ lack of patent-eligible subject matter under 35 U.S.C. § 101 (“Section 101”). Sanderling also asks us to review the district court’s denial of its motion for leave to amend its complaint. We affirm.

UCB, Inc. v. Actavis Laboratories UT, Inc. (Precedential)

This appeal concerns the validity of U.S. Patent No. 10,130,589, directed to transdermal rotigotine patches and asserted by UCB, Inc., UCB Pharma GmbH, and LTH Lohman Therapie-Systeme AG (collectively, “UCB”) in Hatch-Waxman proceedings. UCB sued Actavis Laboratories UT, Inc. (“Actavis”) for infringement based on Actavis’s filing of an Abbreviated New Drug Application. The United States District Court for the District of Delaware found the asserted claims of the ’589 patent invalid for anticipation and obviousness. Because the district court’s fact findings on overlapping ranges, teaching away, unexpected results, and commercial success are not clearly erroneous, we affirm the judgment of invalidity.

Sequoia Technology, LLC v. Dell Inc. (Precedential)

Sequoia Technology, LLC appeals from a stipulated judgment of noninfringement and invalidity of U.S. Patent No. 6,718,436 following an adverse claim construction ruling from the United States District Court for the District of Delaware. For the reasons below, we disagree with the district court’s claim construction for “computer-readable recording medium,” and thus we reverse the district court’s ineligibility determination under 35 U.S.C. § 101. In addition, we agree with the district court’s claim construction for “disk partition” and “logical volume,” and thus we affirm the district court’s noninfringement determination.

Healthier Choices Management Corp. v. Phillip Morris USA, Inc. (Precedential)

In these combined appeals, Healthier Choices Management Corp. challenges the district court’s (1) dismissal of its original complaint, (2) denial of its motion for leave to amend its complaint, and (3) grant of attorneys’ fees. For the reasons below, we reverse the district court’s dismissal of the original complaint and denial of leave to amend. Accordingly, we vacate the award of attorneys’ fees. We remand for further proceedings consistent with this opinion.

Al Ghurair Iron & Steel Inc. v. United States (Precedential)

Al Ghurair Iron & Steel LLC appeals a Court of International Trade judgment affirming a circumvention determination by the U.S. Department of Commerce (“Commerce”). Commerce determined that United Arab Emirates (“UAE”) producers of certain corrosion-resistant steel (“CORE”) were circumventing antidumping (“AD”) and countervailing duty (“CVD”) orders on CORE from China. In making its determination, Commerce analyzed the circumvention factors and subfactors provided by 19 U.S.C. § 1677j(b). AGIS argues that Commerce erroneously analyzed several of these factors and subfactors.

We find that Commerce’s circumvention determination is reasonable and supported by substantial evidence. We conclude that Commerce’s analysis of the “value added” subfactor is erroneous because Commerce did not reasonably explain why it rejected AGIS’s financial data that were purported to show a significant value added. We find that this error was harmless because it was limited to a single factual finding within a multi-factor test. We thus affirm the Court of International Trade’s judgment.

Bluecatbio MA Inc. v. Yantai AusBio Laboratories Co., Ltd. (Nonprecedential)

BlueCatBio MA Inc. (“BlueCat”) appeals from a final written decision of the U.S. Patent and Trademark Office Patent Trial and Appeal Board (“the Board”) holding that claims 1, 3−5, 7, 10−12, and 14−20 of U.S. Patent 10,338,063 had not been shown to have been unpatentable as anticipated or rendered obvious in view of the asserted prior art. For the following reasons, we affirm.