Justia Civil Procedure Opinion Summaries

Koss Corporation (Koss) owns several patents related to wireless earphones. Koss filed a patent infringement lawsuit against Bose Corporation (Bose) in the Western District of Texas, alleging infringement of three patents. Bose challenged the venue and also filed for inter partes review (IPR) of the patents with the Patent Trial and Appeal Board (PTAB). Concurrently, Bose sought a declaratory judgment of noninfringement in the District of Massachusetts. The Texas court dismissed Koss's case for improper venue, leading Koss to file counterclaims in Massachusetts. The Massachusetts court stayed the case pending the IPR outcomes.In parallel, Koss's infringement action against Plantronics, Inc. was transferred to the Northern District of California. Plantronics moved to dismiss the case, arguing that the patents were invalid under 35 U.S.C. § 101. The California court agreed, invalidating all claims of the patents. Koss amended its complaint but eventually stipulated to dismiss the case with prejudice, without appealing the invalidation order.The United States Court of Appeals for the Federal Circuit reviewed the PTAB's decisions on the IPRs. However, since the California court had already invalidated all claims of the patents and Koss did not appeal this decision, the Federal Circuit found the appeals moot. The court held that the invalidation order from the California court was final and precluded any further action on the patents, leading to the dismissal of the appeals. View "KOSS CORPORATION v. BOSE CORPORATION " on Justia Law

Backertop Licensing LLC and Lori LaPray appealed the U.S. District Court of Delaware’s orders requiring LaPray to appear in-person for testimony regarding potential fraud and imposing monetary sanctions for her failure to appear. The District Court identified potential misconduct in numerous related patent cases involving IP Edge and Mavexar, which allegedly created shell LLCs, assigned patents for little consideration, and directed litigation without disclosing their ongoing rights. The court was concerned that this arrangement concealed the real parties in interest and potentially perpetrated fraud on the court.The District Court ordered LaPray, the sole owner of Backertop, to produce documents and appear in-person to address these concerns. LaPray moved to set aside the order, citing travel difficulties and requesting to appear telephonically, which the court denied. The court rescheduled the hearing to accommodate her schedule but maintained the requirement for in-person testimony to assess her credibility. LaPray did not attend the rescheduled hearing, leading the court to hold her in civil contempt and impose a daily fine until she appeared.The United States Court of Appeals for the Federal Circuit reviewed the case. The court held that the District Court’s orders were within its inherent authority and not an abuse of discretion. The court found that Federal Rule of Civil Procedure 45, which limits the geographic range of subpoenas, did not apply to the court’s sua sponte orders. The court affirmed the District Court’s orders, emphasizing the necessity of in-person testimony to investigate potential misconduct and assess credibility. The monetary sanctions for LaPray’s failure to appear were also upheld. View "BACKERTOP LICENSING LLC v. CANARY CONNECT, INC. " on Justia Law

The Chemehuevi Indian Tribe filed a complaint against the United States, alleging mismanagement of funds and breach of trust. The Tribe sought an accounting and damages for the alleged mismanagement of the Parker Dam compensation funds, the Indian Claims Commission (ICC) Judgment funds, and the suspense accounts. The Tribe also claimed that the U.S. government's failure to approve a proposed lease of its water rights constituted a Fifth Amendment taking and a breach of trust.The United States Court of Federal Claims dismissed the Tribe's complaint, ruling that it lacked subject-matter jurisdiction. The court found that the Tribe was essentially seeking an accounting to discover potential claims against the government, rather than asserting a right to be paid a certain sum. The court also dismissed the Tribe's claims related to the proposed water rights lease, stating that the claim was outside the six-year statute of limitations.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the lower court's dismissal of the Tribe's complaint for lack of subject-matter jurisdiction. The appellate court agreed that the Tribe was seeking an accounting to discover potential claims, rather than asserting a right to be paid a certain sum. The court also affirmed the dismissal of the Tribe's claim related to the proposed water rights lease, agreeing that it was outside the statute of limitations. However, the appellate court vacated the lower court's dismissal of the Tribe's claim for failure to state a takings claim, stating that the Tribe's decision to lease the water off-reservation could fulfill the purpose of the reservation. View "CHEMEHUEVI INDIAN TRIBE v. US " on Justia Law

The Portland Mint delivered truckloads of coins to a foundry designated by the United States Mint for redemption under a regulation that provided for the redemption of mutilated coins. The coins were melted down and used to make new coins. However, the U.S. Mint refused to pay for the shipment, claiming that a high percentage of the coins were counterfeit. Portland Mint, asserting that the coins were genuine, brought five claims against the United States in the Court of Federal Claims. The Claims Court dismissed all five claims, concluding that it lacked jurisdiction for the first two claims and that all five claims failed to state a claim upon which relief could be granted.The United States Court of Appeals for the Federal Circuit found that the Claims Court erred in dismissing the second claim for lack of jurisdiction and failure to state a claim. The court held that the regulation under which the coins were submitted created an implied-in-fact contract between Portland Mint and the U.S. Mint, and that the Claims Court had jurisdiction over this claim. The court also held that Portland Mint had sufficiently stated a claim for breach of this implied contract. The court affirmed the dismissal of the remaining three merits claims and did not reach the fifth claim concerning attorneys’ fees. The case was affirmed in part and reversed and remanded in part for further proceedings. View "The Portland Mint v. United States" on Justia Law

The case revolves around Jay Anthony Dobyns, a former agent with the United States Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF), who sued the United States for failing to adequately protect him and his family from threats related to his undercover work. The government counterclaimed, alleging that Dobyns violated his employment contract and several federal regulations by publishing a book based on his experience as an agent and by contracting his story to create a motion picture. The Court of Federal Claims found that the government had not breached the settlement agreement but had breached the covenant of good faith and fair dealing, awarding Dobyns emotional distress damages. The court also found that the government was not entitled to relief on its counterclaim.The government appealed the Claims Court’s judgment to the United States Court of Appeals for the Federal Circuit, which reversed the finding that the government breached the implied duty of good faith and fair dealing. Dobyns, having prevailed on the government’s counterclaim, sought attorneys’ fees and costs. However, the Claims Court denied his application for attorneys’ fees under the Equal Access to Justice Act (EAJA) as untimely. Dobyns appealed this decision.The United States Court of Appeals for the Federal Circuit found that the Claims Court had abused its discretion and applied the incorrect legal standard. The Appeals Court held that the filing deadline for fee applications under EAJA is subject to equitable tolling. It found that Dobyns had justifiably relied on the government's representations about the procedure for Claims Court judgments, and thus his motion for attorneys’ fees under EAJA should be accepted as timely. The court reversed the Claims Court's decision and remanded the case for further proceedings. View "Dobyns v. United States" on Justia Law

The case involves four veterans who appealed from judgments of the United States Court of Appeals for Veterans Claims, which dismissed their petitions for writs of mandamus due to lack of jurisdiction. The veterans' disability ratings were reduced, and they sought to have their original ratings continue pending the final resolution of the validity of the reduction. The veterans argued that the Department of Veterans Affairs (VA) could not lawfully decrease or discontinue their payments until their appeals challenging the reduction were exhausted.The Veterans Court found that there was no basis on which it could issue a writ under the All Writs Act in aid of its jurisdiction. The Veterans Court dismissed the veterans' petitions for lack of jurisdiction. The veterans then appealed to the United States Court of Appeals for the Federal Circuit.The Federal Circuit Court affirmed the Veterans Court's decision. The court held that mandamus relief was not available for the veterans under the All Writs Act because there was an adequate remedy by appeal that the veterans had chosen not to invoke. The court concluded that when there is a remedy by appeal, mandamus is unavailable. The court found that the veterans could have requested relief from the VA, and if a decision had been obtained from the Board denying the requested relief, a remedy by appeal would have been available to the veterans. The court also noted that an appeal is available if three conditions are satisfied: a clear and final decision of a legal issue, the resolution of the legal issues adversely affects the party seeking review, and there is a substantial risk that the decision would not survive a remand. The court found that these conditions would have been satisfied if the veterans had appealed the question of their entitlement to interim payments while the merits of their reductions were still pending. View "LOVE v. MCDONOUGH " on Justia Law

This case involves Packet Intelligence LLC ("Packet") and NetScout Systems, Inc. and NetScout Systems Texas, LLC (collectively, "NetScout"). Packet had sued NetScout for patent infringement. The U.S. District Court for the Eastern District of Texas found that NetScout had willfully infringed Packet's patents and awarded Packet damages, enhanced damages for willful infringement, and an ongoing royalty. NetScout appealed this decision.In a previous appeal, the United States Court of Appeals for the Federal Circuit had reversed the district court's award of pre-suit damages and vacated the court's enhancement of that award. The court affirmed the district court's judgment in all other respects and remanded the case to the district court. On remand, the district court denied NetScout's motion to dismiss or stay the case and entered an amended final judgment. The amended judgment reduced the enhanced damages and reset the ongoing royalty rate.Meanwhile, the Patent Trial and Appeal Board ("Board") found all of the patent claims asserted by Packet in this case unpatentable as obvious. Packet appealed the Board's final written decisions. The Federal Circuit coordinated those appeals so they would be considered by the same panel deciding this appeal.The United States Court of Appeals for the Federal Circuit vacated the district court’s amended final judgment and remanded the case with instructions to dismiss the case as moot. The court held that Packet’s infringement judgment was not final before the Board’s unpatentability determinations were affirmed. Therefore, the court was compelled to order that Packet’s patent infringement claims be dismissed as moot. View "PACKET INTELLIGENCE LLC v. NETSCOUT SYSTEMS, INC. " on Justia Law

The case revolves around SnapRays, a Utah-based company that designs, markets, and sells electrical outlet covers with integrated guide lights, safety lights, motion sensor lights, and USB charging technology, and Lighting Defense Group (LDG), an Arizona-based company that owns a patent related to a cover for an electrical receptacle. LDG submitted an Amazon Patent Evaluation Express (APEX) Agreement alleging that certain SnapPower products sold on Amazon.com infringed its patent. SnapPower subsequently filed an action for declaratory judgment of noninfringement.The United States District Court for the District of Utah dismissed SnapPower's complaint for lack of personal jurisdiction over LDG. The court concluded that LDG lacked sufficient contacts with Utah for it to exercise specific personal jurisdiction. It found that LDG's allegations of infringement were directed toward Amazon in Washington, where the APEX Agreement was sent, and not at SnapPower in Utah. The court also noted that under Federal Circuit law, principles of fair play and substantial justice support a finding that LDG is not subject to specific personal jurisdiction in Utah.The United States Court of Appeals for the Federal Circuit reversed the lower court's decision. The appellate court concluded that LDG purposefully directed extra-judicial patent enforcement activities at SnapPower in Utah, thereby satisfying the requirements for specific personal jurisdiction. The court found that LDG's submission of the APEX Agreement to Amazon, which identified SnapPower's listings as allegedly infringing, was an intentional action aimed at affecting SnapPower's sales and activities in Utah. The court also rejected LDG's argument that the assertion of specific personal jurisdiction over it in Utah would be unfair and unreasonable. The case was remanded for further proceedings. View "SNAPRAYS v. LIGHTING DEFENSE GROUP " on Justia Law

The case revolves around a dispute between Jalmar Araujo and Framboise Holdings Inc. over the registration of the standard character mark #TODECACHO. Araujo filed a U.S. Trademark Application to register #TODECACHO for hair combs. Framboise opposed the registration, claiming that it would likely cause confusion with its #TODECACHO design mark, which it had been using in connection with various hair products since March 24, 2017. Framboise also had a pending trademark application for the same mark.The United States Patent and Trademark Office Trademark Trial and Appeal Board (the Board) granted Framboise an extension to submit its case in chief. Araujo opposed this extension and the late submission of a declaration by Adrian Extrakt, Director of Framboise. However, the Board granted the extension, finding that the delay was minimal and that Framboise had met the applicable good cause standard. The Board then relied on the Extrakt declaration to support Framboise's claim of prior use of the #TODECACHO design mark.The Board found that Framboise had met its burden to establish prior use by a preponderance of the evidence. It found that the Extrakt declaration alone was sufficient to prove prior use because it was clear, convincing, and uncontradicted. Having found an earlier priority date for Framboise, the Board found a likelihood of confusion between the two marks, sustained the opposition, and refused registration of Araujo’s mark.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Board's decision. The court found that the Board did not abuse its discretion in granting the extension and that the Board's finding that Framboise established prior use of the #TODECACHO design mark was supported by substantial evidence. View "ARAUJO v. FRAMBOISE HOLDINGS INC. " on Justia Law

The case involves Tony Lamonte Greene and Billie Wayne Byrd, who are incarcerated in an Oklahoma state prison. They, along with seven co-plaintiffs, filed actions in the Court of Federal Claims, arguing that their imprisonment is unlawful and seeking monetary compensation from the United States. They claim to be members of the Cherokee Nation and argue that under certain treaties between the Cherokee Nation and the United States, the State of Oklahoma lacked jurisdiction to prosecute and incarcerate them. They each seek $100 per day for unauthorized detention and more than $1,000,000 in compensatory and punitive damages.The Claims Court dismissed the plaintiffs’ actions for lack of jurisdiction. The court held that the plaintiffs failed to show that the treaties on which they relied gave rise to a personal right to monetary relief on their part in the event of a breach of the covenants relating to the exercise of civil and criminal jurisdiction within the Cherokee Nation. The court explained that claims based on treaties with Indian nations can fall within the jurisdiction of the Claims Court because they are treated as “a species of contract.” However, the court concluded that the treaties were not money-mandating.The United States Court of Appeals for the Federal Circuit affirmed the decision of the Claims Court. The court found that the treaty provisions the appellants relied upon are not money-mandating. The court also noted that the agreements addressed the respective rights of sovereignty of the two contracting parties; they did not create contract-based rights in individuals, the breach of which could give rise to monetary remedies for those individual complainants. The court concluded that the appellants’ claim does not fall within the reach of the Tucker Act, and therefore, the Claims Court lacked jurisdiction to address their demand for damages from the United States attributable to their prosecution and incarceration by the State of Oklahoma. View "GREENE v. US " on Justia Law