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Motion to Dismiss Federal Rule 12(b)(6)

A&O Shearman

Federal Circuit Provides Guidance On Rule 12(b)(6) Stage Claim Construction

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On October 18, 2024, the U.S. Court of Appeals for the Federal Circuit issued a precedential decision addressing claim construction at the Rule 12(b)(6) stage. In UTTO Inc. v. Metrotech Corp., No. 2023-145 (Fed. Cir. Oct. 18,...more

McDermott Will & Emery

Pre-Markman Claim Construction Is OK, Within Limits

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In an appeal stemming from the denial of a preliminary injunction and dismissal of the complaint, the US Court of Appeals for the Federal Circuit clarified its precedent and explained that a district court may construe claims...more

Law School Toolbox

Bar Exam Toolbox Podcast Episode 286: Listen and Learn -- Conclusory Pleadings Under Rule 12(b)(6) (Civ Pro)

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Welcome back to the Bar Exam Toolbox podcast! Today, as part of our "Listen and Learn" series, we're discussing a topic from Civil Procedure – specifically, when is a pleading conclusory under the Twombly/Iqbal standard for...more

Seyfarth Shaw LLP

New Jersey Destination Charge Case Reaches Final Destination - Seyfarth's Future of Automotive Series

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On Wednesday, October 23, 2024, FCA US LLC, the manufacturer of Chrysler, Jeep, Dodge, Ram vehicles, among others, put the final nail in the coffin of claims by consumers that “destination charges” for the delivery of...more

Womble Bond Dickinson

Federal Circuit: Claim Construction Not Forbidden Per Se at Motion to Dismiss Stage

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On October 18, 2024, the Federal Circuit issued a precedential decision in UTTO Inc. v. Metrotech Corp., No. 2023-145 (Fed. Cir. Oct. 18, 2024), addressing, in relevant part, the propriety of claim construction at the Rule 12...more

Troutman Pepper Locke

The Beginning of the End for False Claims Act Qui Tam Cases? Florida District Judge Holds Whistleblower Provisions...

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On September 30, Judge Kathryn Kimball Mizelle held that the qui tam provision of the False Claims Act (FCA) violates the Appointments Clause of the U.S. Constitution because FCA relators are acting as “officers of the U.S.”...more

Polsinelli

Regeneron v Novartis and Vetter: Walker Process Client Update

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In an appeal that attracted a dozen amici, including the Department of Justice, the Federal Trade Commission, five states, and the District of Columbia, the Second Circuit gave the Walker Process antitrust doctrine a shot in...more

Littler

Second Circuit Further Addresses the Pleading Standard for FLSA Overtime Claims

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Nearly a decade ago, the U.S. Court of Appeals for the Second Circuit issued three decisions clarifying and tightening the standard for asserting plausible overtime claims under the Fair Labor Standards Act (FLSA) in the...more

Morris James LLP

Chancery Sustains M&A Fraud Claims Based On Near-Term EBITDA Projections

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In re P3 Health Grp. Hldgs., LLC, C.A. No. 2021-0518-JTL (Del. Ch. Oct. 26, 2022) - This recent decision addresses three points of interest relevant to fraud claims....more

Knobbe Martens

Plausible Factual Allegations Concerning Inventive Concepts Preclude Motion to Dismiss

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COOPERATIVE ENTERTAINMENT, INC. v. KOLLECTIVE TECHNOLOGY, INC. - Before Moore, Lourie, and Stark. Appeal from the United States District Court for the Northern District of California. - Summary: Plausible allegations...more

Goldberg Segalla

Asbestos Complaint Survives Motion to Dismiss

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U.S. District Court for the Eastern District of North Carolina, Eastern Division, May 13, 2022 The plaintiffs Augustus Adams and his wife brought suit against numerous defendants, alleging that Mr. Adams developed...more

Akin Gump Strauss Hauer & Feld LLP

District Court Granted Dismissal Because the Patent Recited a Patent-Ineligible Abstract Idea of Processing and Transmitting Data

Chief Judge Lynn in the Northern District of Texas recently granted a Rule 12(b)(6) motion to dismiss a complaint alleging patent infringement because the claim-at-issue recites patent-ineligible subject matter under 35...more

Proskauer - Corporate Defense and Disputes

Cisco Diversity Suit Dismissed

Another shareholder derivative suit claiming diversity shortcomings within the company was dismissed last week: A judge in the Northern District of California dismissed allegations that Cisco Systems Inc. falsely and...more

Carlton Fields

How to Avoid Getting Shot Down – A Primer on Shotgun Pleadings

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The Eleventh Circuit recently reaffirmed its stance on shotgun pleadings, reiterating in Barmapov v. Amuial that district courts are within their discretion to dismiss with prejudice a shotgun pleading filed by a litigant...more

Hogan Lovells

Blue Cube Spinco v. Dow Chemical: Indemnification allegation sufficient for breach of contract claim - Quarterly Corporate / M&A...

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In Blue Cube Spinco LLC v. The Dow Chemical Company, C.A. No. N21C-01-214 PRW CCLD (Del. Sup. Ct. Sept. 29 2021), the Delaware Superior Court found that an M&A buyer had adequately alleged breach of contract claims for a...more

Seyfarth Shaw LLP

Computers on Wheels: Complaint Against Auto Manufacturer For Allegedly Botched Software Update Survives (For Now)

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A federal court in Georgia recently denied a motion to dismiss filed by an auto manufacturer seeking to avoid a putative class action lawsuit filed by an owner who claimed that an allegedly botched over-the-air (OTA) software...more

Womble Bond Dickinson

District of Delaware Judge Stops Practice of Referring Certain 12(b)(6) Motions to Magistrates

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In recent years, District of Delaware Judges, including Judge Richard Andrews, have helped to manage the high volume of patent litigation cases by referring 12(b)(6) motions to dismiss to Magistrate Judges. Last week, in...more

Freeman Law

Reasonable Cause: An Estate’s Defense Against IRS’s Late-Filing Penalties

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The Internal Revenue Code (the “Code”) contains over 150 civil tax penalties for various conduct and non-conduct. One common group of penalties, associated with the late filing of a tax return and the late payment of tax,...more

Akin Gump Strauss Hauer & Feld LLP

Overlooked Patent Cases: Indirect Infringement Developments

Allegations of indirect patent infringement require, among other things, pleading that the defendant had knowledge of the asserted patent. It is not well-settled law, however, whether notice of a complaint itself satisfies...more

Akin Gump Strauss Hauer & Feld LLP

The Eastern District of Texas Granted a Rule 12(b)(6) Dismissal Because the Asserted Patent Was Directed to the Patent-Ineligible...

A district court in the Eastern District of Texas granted a Rule 12(b)(6) motion to dismiss computer-implemented claims as patent-ineligible abstract ideas under 35 U.S.C. § 101. The Patent is directed to credentialing...more

Troutman Pepper Locke

Western District of Washington Denies Defendant’s Motion to Dismiss Based on Plaintiff’s Allegations That She Did Not Owe the Debt

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In Tinsley v. Fairway Collections, LLC, the Western District of Washington recently issued an opinion finding that dismissal of a consumer’s FDCPA claim was not warranted because she alleged not owing the underlying debt at...more

Fox Rothschild LLP

Chief Judge Stark Denies Defendants’ Motions To Dismiss Plaintiff’s Complaints Asserting Patent Infringement Due To The Use Of...

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By Memorandum Opinion entered by The Honorable Leonard P. Stark in Stragent, LLC v. BMW of North America, LLC et al., Civil Action No. 20-510-LPS (D.Del. March 25, 2021) (consolidated), the Court denied Defendants’ motions to...more

Downs Rachlin Martin PLLC

Vermont Supreme Court Issues Important Decision On The Enforceability Of Arbitration Clauses In Consumer Agreements And The...

The Court Affirmed A Lower Court’s Enforcement Of The Arbitration Clause, Requiring The Consumers To Arbitrate Their Claims Against A Home Inspection Company, And Also Affirmed The Lower Court’s Refusal To Vacate The...more

Rosenberg Martin Greenberg LLP

West Virginia Supreme Court Rejects Federal “Plausible On Its Face” Standard For Motions to Dismiss Under State Counterpart of...

The Rules of Civil Procedure adopted by the West Virginia Supreme Court of Appeals are derived to a large extent from the Federal Rules of Civil Procedure.  In fact, many of the West Virginia Rules of Civil Procedure track...more

Akin Gump Strauss Hauer & Feld LLP

District Court Denied Rule 12(b)(6) Motion Based on Section 101 Because Additional Facts and Claim Construction Would Provide...

While a district court in California remained “skeptical” of the patent eligibility of three computer-implemented patents, the court denied a Rule 12(b)(6) motion to dismiss under 35 U.S.C. § 101. The court found that claim...more

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