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En Banc Federal Circuit Cools Damages Award Because of Improper Expert Testimony

In an en banc decision in EcoFactor, Inc. v. Google LLC, the US Court of Appeals for the Federal Circuit concluded that the district court abused its discretion by admitting testimony from a damages expert that a lump-sum...more

Designated Informative: PTO Director Declines IPR Institution Following District Court § 101 Invalidation

The US Patent & Trademark Office (PTO) designated a recent Director Review decision as informative, signaling its significance for future proceedings. The decision emphasizes that a final district court ruling invalidating a...more

“Payment Handler”: A Nonce Term Without Instructions

The US Court of Appeals for the Federal Circuit affirmed a district court’s ruling that a software term was a “nonce” term that invoked 35 U.S.C. § 112, sixth paragraph (i.e., a means-plus-function claim element). The Court...more

Broadcast Alert! Applying Conventional Machine Learning to New Data Isn’t Patent Eligible

The US Court of Appeals for the Federal Circuit affirmed a district court’s ruling that patents applying established machine learning methods to new data are not patent eligible under 35 U.S.C. §101. Recentive Analytics, Inc....more

When Is a Trade Secret Accessible? As Soon as It Can Be Reverse Engineered

Although the US Court of Appeals for the Federal Circuit upheld a damages award for trade secret misappropriation and breach of a confidentiality agreement, it found that the district court erred in its determination of when...more

Human Authorship Required: AI Isn’t an Author Under Copyright Act

The US Court of Appeals for the District of Columbia upheld a district court ruling that affirmed the US Copyright Office’s (CO) denial of a copyright application for artwork created by artificial intelligence (AI),...more

Collateral Estoppel Doesn’t Apply to Unchallenged IPR Claims

The US Court Appeals for the Federal Circuit found that despite a Patent Trial & Appeal Board determination that certain challenged patent claims were unpatentable based on a preponderance of the evidence standard, the patent...more

Uncompleted Building Sold in Bankruptcy Doesn’t Infringe Architect’s Copyright

The US Court of Appeals for the Eighth Circuit affirmed a district court’s ruling that there was no actionable infringement where an uncompleted building sold under the authority of a bankruptcy court was later completed....more

Serving a Perfect 10: No Protection for Embedding

The US Court of Appeals for the Ninth Circuit found that a photo- and video-sharing social networking service could not be liable for secondary copyright infringement because embedding a photo does not “display a copy” of the...more

Transfer Motions Take Priority Regardless of Target District

The US Court of Appeals for the Federal Circuit granted a writ of mandamus and ordered the district court to decide a motion for intra-district transfer before proceeding to further substantive matters, explaining that both...more

Message to Judge Albright: Venue Motions Are First Order of Business

The US Court of Appeals for the Federal Circuit vacated a scheduling order from the US District Court for the Western District of Texas and directed the court to postpone fact discovery and other substantive proceedings until...more

Seeing Starz: No Damages Bar in Copyright Discovery Rule Case

The US Court of Appeal for the Ninth Circuit affirmed a district court’s denial of a motion to dismiss copyright infringement claims as barred by the statute of limitations, affirming the copyright owner’s right to sue even...more

No Winners Here: A Case Can Have No Prevailing Party

In a matter of first impression, the US Court of Appeals for the Eleventh Circuit found that there may be no prevailing party for purposes of assessing costs and attorneys’ fees under Federal Rule of Civil Procedure 54(d)....more

Patent Infringement Verdict Nixed over Judge’s Stock Ownership

The US Court of Appeals for the Federal Circuit reversed a district court’s opinions and orders and remanded the case for further proceedings before a different district court judge because the original judge had failed to...more

There Should Be No Secret about Scope of Trade Secret Injunction

In the context of an interlocutory appeal, the US Court of Appeals for the Federal Circuit vacated a portion of a preliminary injunction in a case involving alleged misappropriation of trade secrets for failing to provide...more

The Perils of Falling in Love

The US Court of Appeals for the Second Circuit affirmed the dismissal of a lawsuit that sought a declaratory judgment on the basis that a notice of termination of copyright assignment under 17 U.S.C. § 203 did not validly...more

First Sale Defense Bars Trademark Infringement Where Trademarked Component Is Adequately Disclosed

A US Court of Appeals for the Ninth Circuit panel vacated a grant of summary judgment in favor of the plaintiff, holding that the first sale doctrine applies when a trademarked product is incorporated into a new product....more

So You Wanna Play with Copyright? “Joyful Noise” Ostinato Isn’t Original Expression

The US Court of Appeals for the Ninth Circuit affirmed a district court’s order vacating a jury award of damages for copyright infringement and granting judgment as a matter of law, explaining that the musical work alleged to...more

Copyright Act's Safe Harbor Protects against Unknown Inaccuracies of Facts or Law

The Supreme Court of the United States held that lack of factual or legal knowledge can excuse an inaccuracy in a copyright registration under a safe harbor contained in the Copyright Act. As a result, an applicant’s...more

What a Deal! Car Dealers Retain Control over Their Own Data

The US Court of Appeals for the Ninth Circuit affirmed a district court’s conclusion that there is no conflict between an Arizona statute aimed at strengthening privacy protections for consumers whose data is collected by car...more

Authentication Claim Under Alice—A Two-Step Process

The US Court of Appeals for the Federal Circuit found patent claims directed to a method of authenticating the identity of a user performing a transaction at a terminal was patent-eligible under 35 U.S.C. § 101 and reversed...more

De Minimis Defense Doesn’t Protect Minimal Use of Concededly Infringing Material

The US Court of Appeals for the Ninth Circuit reversed a district court’s grant of summary judgment in favor of the defendant in a copyright case based on a “minimal usage” or de minimis use defense. Richard N. Bell v....more

Damage Expert Testimony Excluded for Failure to Disclose Evidence and to Apportion

The US Court of Appeals for the Federal Circuit affirmed a district court’s decision to preclude a damage expert from characterizing license agreements and opining on a reasonable royalty rate where the sponsoring party...more

Absent Proof of Government Ownership on an EEA Sovereign Immunity Defense is All Black and White

The US Court of Appeals for the Ninth Circuit affirmed the district court’s denial of a motion to dismiss an indictment, charging four Chinese companies with violations of the criminal provisions of the Economic Espionage Act...more

Federal Circuit Puts Patent Infringement Award/Injunction Back in the Box

The US Court of Appeals for the Federal Circuit, exploring the use of Federal Rule of Civil Procedure 60(b)(3) under Ninth Circuit law, affirmed a district court’s ruling setting aside a monetary damages judgment and an...more

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