Case Summaries

[02/01] Thorner v. Sony Computer Entertainment America LLC
In a patent infringement action concerning a patent relating to a tactile feedback system for computer video games, the district court's judgment of noninfringement upon stipulation is vacated and the case remanded, where: 1) the district court improperly limited the term "attached to said pad" to mean attachment only to an external surface, and the parties based the stipulation of noninfringement on the district court's erroneous construction of this claim; and 2) the district court erred in its construction of the term "flexible."

[01/27] Krippelz v. Ford Motor Co.
In a patent infringement case involving a vehicle-mounted lamp, the district court's denial of the defendant's motion for judgment as a matter of law on invalidity is reversed, its summary judgment of infringement is vacated, and the case is remanded for entry of judgment of nonliability for the defendant, where the district court committed reversible error in its holdings that: 1) a reasonable jury could find that a competing French patent failed to teach the required "conical beam of light;" and 2) the jury could have reasonably found the French patent to lack a lamp "adjacent to the window."

[01/23] Falana v. Kent State University
In a suit against a university and inventors listed on a patent alleging that the plaintiff was an omitted co-inventor, the district court’s judgment in favor of the plaintiff as to inventorship is affirmed, where: 1) the district court did not err in construing the language of the claims; 2) error in the exclusion of certain exhibits did not result in substantial injustice and was harmless error; 3) the district court did not err in concluding that the plaintiff's contribution of the method used by the team of which he was a part for making the claimed compounds was enough of a contribution to conception to pass the threshold required for joint inventorship; and 4) the district court's exceptional case finding and award of attorney fees were not yet final and not properly before the court of appeals.

[01/20] Dealertrack, Inc. v. Huber
In a patent infringement action involving patents directed to a computer-aided method and system for processing credit applications over electronic networks, the district court's rulings on summary judgment motions are affirmed in part, vacated in part, reversed in part, and the case remanded, where: 1) the district court erred in granting summary judgment of noninfringement based on a construction of "communications medium" that carved out the Internet; 2) the court modified the claim constructions of "communications medium" and "central processing means," requiring it to vacate summary judgment of noninfringement and remand to the district court to determine infringement in the first instance applying the new constructions; 3) the district court legally erred in denying a motion for summary judgment of invalidity of certain claims for indefiniteness; 4) the district court correctly found that certain claims were patent ineligible abstract ideas.

[01/19] Washington State Republican Party v. Washington State Grange
In a suit involving the State of Washington's "top-two" primary election system, the district court's order granting the state's request for reimbursement of attorney's fees is reversed, and its summary judgment dismissal of the plaintiff's claims in other respects is affirmed, where: 1) the state showed that its primary system furthered an important regulatory interest in providing voters with relevant information about the candidates on the ballots, so as to defeat the plaintiffs' as-applied freedom of association claims; 2) the state's primary system did not violate its fundamental right of access to the ballot by making it difficult for a minor-party candidates to qualify for the general election ballot; 3) a plaintiff did not explain how the state infringed its trademark in connection with the provision of competing services; 4) a written settlement definitively resolved the state's liability for attorney's fees; 5) the district court did not abuse its discretion in denying leave to amend the complaint to add a new claim; 6) the plaintiffs waived a claim concerning compelled speech because it was not included in any complaint; and 7) the primary system was severable from an unconstitutional provision of the same enacting legislation.

[01/18] Golan v. Holder
In a suit by orchestra conductors, musicians, publishers, and others who formerly enjoyed free access to literary and artistic works removed from the public domain by section 514 of the Uruguay Round Agreements Act, the Tenth Circuit's reversal of a grant of summary judgment to the plaintiffs is affirmed, as: 1) section 514 does not exceed Congress’s authority under the Copyright Clause; and 2) the First Amendment does not inhibit the restoration of foreign works to copyright protection by section 514.

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