Justia Civil Procedure Opinion Summaries

Trudell Medical International Inc. (Trudell) owns U.S. Patent No. 9,808,588, which relates to devices for performing oscillatory positive expiratory pressure (OPEP) therapy. Trudell sued D R Burton Healthcare, LLC (D R Burton) for patent infringement. D R Burton sells OPEP devices, including the vPEP®, vPEP® HC, iPEP®, PocketPEP®, and PocketPEP® Advantage products. Trudell alleged that these products infringed certain claims of the ’588 patent.The United States District Court for the Eastern District of North Carolina allowed D R Burton to present infringement testimony by Dr. John Collins at trial. After a three-day trial, the jury found that the asserted claims of the ’588 patent were valid but not infringed. Trudell filed a renewed motion for judgment as a matter of law (JMOL) on infringement or, alternatively, for a new trial. The district court denied this motion.The United States Court of Appeals for the Federal Circuit reviewed the case. The court held that the district court abused its discretion by allowing Dr. Collins to testify on noninfringement because his testimony was untimely and did not comply with Federal Rule of Civil Procedure 26. Additionally, the court found Dr. Collins' testimony unreliable under Federal Rule of Evidence 702. The Federal Circuit vacated the jury’s finding of noninfringement and remanded for a new trial, excluding Dr. Collins’ noninfringement testimony. The court also affirmed the district court’s denial of Trudell’s motion for JMOL of infringement, as the jury could have reasonably found noninfringement based on the evidence presented.The Federal Circuit ordered that the case be reassigned to a different district court judge on remand to preserve the appearance of justice and fairness, given the trial judge’s statements indicating a predisposition to quickly resolve the case. View "TRUDELL MEDICAL INTERNATIONAL INC. v. D R BURTON HEALTHCARE, LLC " on Justia Law

Pie Development, L.L.C. was formed to develop an application to streamline the process of purchasing workers compensation insurance. The company alleged that Dax Craig, a consultant, stole the idea and shared it with John Swigart. Craig and Swigart then used the idea to create Pie Insurance Holdings, Inc. and other affiliated entities, generating significant profits. Pie Development sued Craig, Swigart, Pie Insurance Holdings, and Pie Insurance Services, alleging misappropriation of trade secrets under the Mississippi Uniform Trade Secrets Act (MUTSA) and the federal Defend Trade Secrets Act (DTSA), among other claims.The United States District Court for the Southern District of Mississippi dismissed the complaint for failing to provide sufficient detail on each claim, but allowed Pie Development to amend its complaint within thirty days. Pie Development chose not to amend and instead appealed. The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision, noting that Pie Development did not sufficiently plead that it took reasonable measures to protect its business plan's secrecy.While the appeal was pending, Pie Development filed a new lawsuit against additional defendants, including Pie Carrier Holdings, Gallatin Point Capital, Sirius Point Ltd., and Pie Casualty Insurance Company, and later added the original defendants. The district court dismissed the new claims, citing res judicata, as the claims were identical to those in the first lawsuit. Pie Development appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that res judicata applied because the prior action was concluded by a final judgment on the merits when Pie Development chose to appeal rather than amend its complaint. The court also found that Pie Development failed to state a claim against Gallatin and Sirius, as the complaint did not plausibly allege that they knew or should have known about the misappropriation of trade secrets. View "Pie Development v. Pie Carr Holdings" on Justia Law

Steuben Foods, Inc. (Steuben) filed a complaint in 2010 in the United States District Court for the Western District of New York, alleging that Shibuya Hoppmann Corp. infringed claims of U.S. Patent Nos. 6,209,591, 6,536,188, and 6,702,985. Shibuya Kogyo Co., Ltd. was added as a defendant in 2012, and a similar complaint was filed against HP Hood LLC. The cases were consolidated and later transferred to the District of Delaware in 2019. The district court issued a claim construction order in 2020 and denied cross-motions for summary judgment in 2021. A five-day jury trial resulted in a verdict that the asserted patents were valid and infringed, awarding Steuben $38,322,283.78 in damages.The district court granted Shibuya’s motion for judgment as a matter of law (JMOL) of noninfringement for all asserted patents, found the invalidity arguments waived, and conditionally granted a new trial. Steuben appealed the JMOL and the conditional grant of a new trial.The United States Court of Appeals for the Federal Circuit reviewed the case. The court reversed the JMOL of noninfringement for the ’591 and ’188 patents, finding substantial evidence supported the jury’s verdict of infringement. The court affirmed the JMOL of noninfringement for the ’985 patent, holding that the continuous addition of sterilant could not be equivalent to the claim’s requirement of intermittent addition. The court also reversed the conditional grant of a new trial on noninfringement and vacated the conditional grant of a new trial on invalidity and damages, remanding for further proceedings.The main holdings were: reversing the JMOL of noninfringement for the ’591 and ’188 patents, affirming the JMOL of noninfringement for the ’985 patent, reversing the conditional grant of a new trial on noninfringement, and vacating the conditional grant of a new trial on invalidity and damages. View "STEUBEN FOODS, INC. v. SHIBUYA HOPPMANN CORPORATION " on Justia Law

Charles James, a home designer, claimed that real estate agents infringed his copyrights by including floorplans of his homes in resale listings. James designed a home with a triangular atrium and stairs, built six homes using the design, and registered copyrights for the designs. In 2010, agent Susan Horak listed one of these homes for resale, creating a floorplan by hand for the listing. In 2017, agent Jackie Bulgin listed another of James's homes, using a similar floorplan. James discovered these listings in 2017 and alleged that the floorplans could be used to build homes, potentially infringing his copyrights.The United States District Court for the Western District of Missouri granted summary judgment to the real estate agents, concluding that their use of the floorplans was fair use. The court also initially ruled in favor of the agents under § 120(a) of the Copyright Act, but this decision was reversed by the United States Court of Appeals for the Eighth Circuit, which remanded the case for further consideration of the fair use defense.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's summary judgment in favor of the agents. The court held that the agents' use of the floorplans was fair use, considering the purpose and character of the use, the nature of the copyrighted work, the amount and substantiality of the portion used, and the effect on the market for the original work. The court found that the agents' use was transformative, had an informational purpose, and did not harm the market for James's designs. The court also rejected Designworks's request for further discovery on the fair use issue, concluding that the district court did not abuse its discretion in denying the motion. The court affirmed the district court's judgments. View "Designworks Homes, Inc. v. Columbia House of Brokers Realty, Inc." on Justia Law

Silverthorne Seismic, L.L.C. licensed seismic data to Casillas Petroleum Resource Partners II, L.L.C. and sent the data to Sterling Seismic Services, Ltd. for processing. Silverthorne alleged that Sterling sent unlicensed data to Casillas, which Casillas then showed to potential investors. Silverthorne sued Sterling for trade-secret misappropriation under the Defend Trade Secrets Act, seeking a reasonable royalty as a remedy.The United States District Court for the Southern District of Texas set the standard for calculating a reasonable royalty, adopting a definition from a previous case, University Computing Co. v. Lykes-Youngstown Corp. The district court certified this order for interlocutory appeal under 28 U.S.C. § 1292(b), concluding that the reasonable-royalty standard was a controlling question of law with substantial ground for difference of opinion and that an immediate appeal would materially advance the litigation. The district court stayed the proceedings pending the appeal, and an administrative panel of the United States Court of Appeals for the Fifth Circuit granted leave to appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that granting leave to appeal was an error. The court found that the district court's order did not involve a controlling question of law and that the appeal would not materially advance the ultimate termination of the litigation. The court emphasized that the parties had not yet gone to trial, and Silverthorne had not proven liability, making the damages issue premature. The court vacated the order granting leave to appeal, dismissed the appeal for lack of jurisdiction, and remanded the case for further proceedings. View "Silverthorne v. Sterling Seismic" on Justia Law

LegalForce RAPC Worldwide, P.C. ("LegalForce USA"), a California S corporation operating legal services websites, sued LegalForce, Inc. ("LegalForce Japan"), a Japanese corporation providing legal software services, for trademark infringement. LegalForce USA alleged that LegalForce Japan's U.S. expansion plans, website ownership, and advertising and selling of equity infringed its trademark. The district court dismissed the website claims for lack of jurisdiction and the expansion plan claims as unripe. The claims concerning equity were dismissed for failure to state a claim.The United States District Court for the Northern District of California dismissed all claims except those related to the advertising and selling of equity. The court held that it had jurisdiction over these claims but dismissed them for failure to state a claim, reasoning that advertising and selling equity is not connected to the sale of goods or services and thus cannot constitute trademark infringement. The court also found that LegalForce USA failed to justify an extraterritorial application of the Lanham Act.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The court held that using a trademark in connection with the sale of equity does not constitute using the mark in connection with "goods or services" under the Lanham Act. The court also affirmed that LegalForce Japan's services in Japan could not satisfy the "in connection with" goods or services requirement under the Lanham Act, as the relevant conduct occurred outside U.S. territory. The court concluded that the Lanham Act does not apply extraterritorially in this context. View "LEGALFORCE RAPC WORLDWIDE, PC V. LEGALFORCE, INC." on Justia Law

Sysco Machinery Corp. ("Sysco"), a Taiwanese company, sued two other Taiwanese companies, Cymtek Solutions, Inc. ("Cymtek") and Cymmetrik Enterprise Co. Ltd. ("Cymmetrik"), in the U.S. District Court for the District of Massachusetts. Sysco alleged that Cymtek and Cymmetrik infringed its copyrights and misappropriated its trade secrets related to a rotary die-cutting machine developed in Taiwan. The alleged infringing activities occurred in Taiwan, but Sysco claimed that the effects of these activities extended to the United States.Sysco initially pursued legal action in Taiwan's Intellectual Property and Commercial Court (IPCC) and obtained a preliminary injunction against Cymtek and its employees. However, the proceedings in Taiwan are ongoing. Sysco then filed a lawsuit in the U.S. District Court for the Eastern District of North Carolina, which it voluntarily dismissed. Subsequently, Sysco filed the current lawsuit in the District of Massachusetts, asserting claims of trade secret misappropriation, copyright infringement, unfair and deceptive acts, and tortious interference.The U.S. District Court for the District of Massachusetts dismissed the case under the doctrine of forum non conveniens, concluding that Taiwan was a more appropriate forum for the dispute. Sysco appealed the dismissal to the United States Court of Appeals for the First Circuit.The First Circuit reviewed the district court's decision for abuse of discretion and affirmed the dismissal. The court held that Taiwan was an adequate alternative forum, as it could exercise jurisdiction over the parties and provide sufficient remedies for the alleged intellectual property violations. The court also found that the private and public interest factors favored litigation in Taiwan, given that the majority of evidence and witnesses were located there, and the alleged infringing activities primarily occurred in Taiwan. The court concluded that the district court did not abuse its discretion in applying the doctrine of forum non conveniens. View "Sysco Machinery Corp. v. Cymtek Solutions, Inc." on Justia Law

Teradata Corporation sued SAP SE, alleging that SAP illegally conditioned sales of its business-management software (S/4HANA) on the purchase of its back-end database engine (HANA) in violation of Section 1 of the Sherman Act and misappropriated Teradata’s trade secrets under the California Uniform Trade Secrets Act. Teradata claimed that SAP’s tying arrangement forced customers to buy HANA, harming competition in the enterprise data warehousing (EDW) market. Teradata also alleged that SAP used its confidential batched merge method, a technique for efficient data aggregation, without authorization.The United States District Court for the Northern District of California granted summary judgment in favor of SAP. The court excluded Teradata’s expert testimony on market definition and market power, finding the methodology unreliable. Without this testimony, the court concluded that Teradata failed to create a material dispute on its tying claim. The court also ruled against Teradata on the trade secret claim, stating that Teradata did not properly designate the batched merge method as confidential and that the agreements between the parties gave SAP the right to use the method.The United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment. The appellate court held that the district court abused its discretion by excluding the expert’s testimony, which was based on reasonable methodologies. The court found that Teradata raised a triable issue regarding SAP’s market power in the tying market and the anticompetitive effects in the tied market. The court also determined that there were material factual disputes regarding whether Teradata properly designated the batched merge method as confidential and whether the agreements allowed SAP to use the method. The case was remanded for further proceedings. View "TERADATA CORPORATION V. SAP SE" on Justia Law

Phoenix Lighting Group, L.L.C. (Phoenix) sued Genlyte Thomas Group, L.L.C. (DCO) and obtained a jury verdict for tortious interference, misappropriation of trade secrets, and civil conspiracy. The jury awarded Phoenix compensatory and punitive damages, as well as reasonable attorney fees. The trial court awarded additional punitive damages for the misappropriation claim and enhanced the attorney fees by a multiplier of two.The Ninth District Court of Appeals affirmed the trial court's decision in part but reversed the application of the punitive-damages cap for the conspiracy claim, remanding the case for further proceedings. Phoenix requested postjudgment attorney fees, which the Ninth District did not specifically address but remanded the case for further proceedings consistent with its opinion.The Supreme Court of Ohio accepted jurisdiction over DCO's challenge to the enhancement of the attorney-fee award. The court reversed the Ninth District's affirmation of the enhanced attorney fees and remanded the case to the trial court to issue a final judgment granting Phoenix attorney fees in the amount of $1,991,507.On remand, the trial court awarded Phoenix postjudgment attorney fees and expenses. The Ninth District affirmed this award, concluding that the trial court had jurisdiction to consider postjudgment attorney fees and did not exceed its authority.The Supreme Court of Ohio reviewed the case and held that the trial court exceeded its authority by considering and granting Phoenix's motion for postjudgment attorney fees and expenses. The court reversed the Ninth District's judgment and remanded the case to the trial court with instructions to vacate its award of postjudgment attorney fees and expenses and to enter final judgment. View "Phoenix Lighting Group, L.L.C. v. Genlyte Thomas Group, L.L.C." on Justia Law

CPC Patent Technologies Pty Ltd. sought discovery from Apple Inc. under 28 U.S.C. § 1782 for use in a prospective patent infringement lawsuit in Germany. CPC aimed to obtain documents describing the functionality of Apple’s biometric security technology. The district court granted CPC’s application, allowing them to serve a subpoena on Apple, but the scope of the discovery and the specific documents Apple must produce remained unresolved.Initially, a magistrate judge denied CPC’s application, finding the discovery requests unduly burdensome. CPC sought review, and the district court affirmed the magistrate judge’s decision under a clear error standard. On appeal, the Ninth Circuit held that the district court should have reviewed the magistrate judge’s decision de novo, as the ruling on a § 1782 application is dispositive. The case was remanded, and the district court, applying de novo review, granted CPC’s application. Apple objected, particularly concerned about the potential requirement to produce source code, but the district court’s order did not definitively resolve these objections.The United States Court of Appeals for the Ninth Circuit reviewed the case and dismissed the appeal for lack of appellate jurisdiction. The court held that the district court’s decision was not final because the scope of discovery and the specific documents Apple must produce were still undetermined. The lack of a final judgment meant that the Ninth Circuit could not evaluate the Intel factors used to determine whether discovery was warranted under § 1782. Consequently, the appeal was dismissed, leaving the district court to resolve the remaining discovery issues. View "CPC PATENT TECHNOLOGIES PTY LTD. V. APPLE INC." on Justia Law