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Twombly/Iqbal Pleading Standard

Fish & Richardson

Texas Round-Up: September 2025

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The September 2025 edition of our Texas Round-Up focuses on developments in cases involving jurisdiction and pleadings....more

Baker Botts L.L.P.

Examining the Level of Detail Required to Plead a Claim Under the Doctrine of Equivalents

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Patentees face many challenges in trying to prove literal infringement, particularly when dealing with competitors who make trivial modifications or superficial changes to the patented invention. In such situations, the...more

McDermott Will & Schulte

Penny for your characters? Victorian tropes not so striking or protectable

The US Court of Appeals for the Ninth Circuit affirmed a district court’s dismissal of a copyright infringement claim finding that the plaintiff had not plausibly alleged copying of protected characters. Anna Biani v....more

Tyson & Mendes LLP

Flaming Hot Mess or Temporary Indigestion? Montañez v. PepsiCo and the Legal Fight for Credit for the Creation of Flamin’ Hot...

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On May 29, 2025, PepsiCo won at least a reprieve, obtaining an order of dismissal of a former executive’s lawsuit. The former executive claimed the snack food and beverage giant defrauded and defamed him by denying he created...more

Troutman Amin LLP

MORE REQUIRED: Court Tosses TCPA DNC Claim Finding Allegation of “Solicitation” Insufficient

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The bar for pleading solicitations in TCPA DNC cases may have just been raised a smidge. In Bell v. Hawx Services, 2025 WL 2533371 (E.D. Cal Sept. 3, 2025) a court dismissed a TCPA DNC case finding allegations the calls at...more

Marshall Dennehey

Federal Court Dismisses Negligent Entrustment Claim as Speculative and Lacking Factual Support

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Uslu v. Evans, 24-CV-5482, 2025 WL 378919 (E.D. Pa. Jan. 31, 2025) - This case involved a vehicle owned by the co-defendant that allegedly rear-ended the plaintiff’s vehicle. The plaintiff brought action against the...more

White & Case LLP

Ninth Circuit Relaxes Standard for Pleading Federal Trade Secrets Claims in California

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In California trade secrets cases, parties almost always fight about the scope of alleged trade secrets because a state statute requires identification of secrets “with reasonable particularity” before discovery. But in...more

WilmerHale

Readily Ascertainable - WilmerHale's Trade Secret Bulletin: July 2025

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Welcome to WilmerHale’s bulletin on recent trade secret case law and relevant news items. We’ve affectionately nicknamed it “Readily Ascertainable” because, unlike a trade secret, it should be easy to figure out....more

Akin Gump Strauss Hauer & Feld LLP

D. Mass.: Knowledge of Parent Patent, by Itself, May Not Suffice to Show Knowledge of Child Patent for Purposes of Indirect and...

In considering a motion to dismiss infringement claims for two related patents, the District of Massachusetts recently held that pre-suit knowledge of a “parent” patent, without more, is insufficient to establish pre-suit...more

Akin Gump Strauss Hauer & Feld LLP

District Court in 9th Circuit Finds That Heightened Pleading Standard Applies to All Prongs of False Patent Marking Claim

The Central District of California ruled that the heightened pleading standard of Federal Rule of Civil Procedure Rule 9(b) applies to all three prongs of a false patent marking claim, including the third prong, competitive...more

Dorsey & Whitney LLP

Trader Joe’s Labor Union Bags a Victory in Trademark Dispute

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Trader Joe’s is a hugely popular grocery chain that has expanded from its Southern California origins to operate close to 600 stores across the United States. Although Trader Joe’s has traditionally had a reputation as an...more

Seyfarth Shaw LLP

FLSA Pleading:  Mathematical Precision Not Required

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Seyfarth Synopsis: The Supreme Court’s decision in Iqbal on the requirement of specificity in pleading provided the guidance that “determining whether a plausible claim has been pled is a context-specific task that requires...more

Fish & Richardson

District of Delaware Finds Non-Orange Book-Listed Patents Subject to the Same Pleading Standard as Listed Patents in ANDA...

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As part of the Hatch-Waxman Act, given the lack of information on the allegedly infringing product, courts have found that patentees can satisfy the pleading requirements of Twombly/Iqbal without having access to the accused...more

FordHarrison

Second Circuit Panel Adopts Seemingly Heightened Pleading Standard for Willfulness in FLSA Overtime Cases

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Executive Summary: On April 27, 2021, a sharply divided panel of the U.S. Court of Appeals for the Second Circuit, covering New York, Vermont, and Connecticut, held that in Fair Labor Standards Act Overtime cases (FLSA), to...more

Cozen O'Connor

The Sixth Circuit Tackles Twombly, Iqbal And The Malfunction Theory

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Most states have adopted a version of what is typically referred to as the “Malfunction Theory” that permits circumstantial proof of a product defect in a product liability action. The Malfunction Theory largely corresponds...more

Sheppard Mullin Richter & Hampton LLP

Patent Infringement Pleading Standards Remain Unsettled Five Years After the Abrogation of Form 18 – Part 2: Pleading Standards in...

December 1, 2020 marked the five-year anniversary of the Supreme Court’s abrogation of Form 18—the model complaint that provided the minimum requirements for stating a claim of direct infringement. Following the abrogation...more

Haug Partners LLP

Clarifying the Scope of the Parallel Claim Exception to Federal Regulatory Preemption of Medical Devices

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Medical device manufacturers who seek to dispose of meritless claims at the initial pleading stage have long relied upon the doctrine of federal regulatory preemption. This doctrine is embodied by 21 U.S.C. § 360k(a), the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Helms-Burton Lawsuits: Recent Decisions Clarify the Statute’s Limits as Claims Continue

In May 2019, the United States government made available a private right of action under Title III of the Cuban Liberty and Democratic Solidarity (Libertad) Act of 1996 (also known as Helms-Burton), 22 U.S.C. §§ 6021-6091....more

Cozen O'Connor

Defending Institutional Bad Faith Claims, Part II – Focusing on Plausibility

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In Part I of this series, we discussed institutional bad faith and best practices for insurers to minimize the risk of these costly and intrusive lawsuits. In Part II, we will focus on cutting discovery off at the...more

Robins Kaplan LLP

The Second Circuit Eliminates Iqbal Hearings

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The Second Circuit has breathed new life into Sarah Palin’s case against the New York Times by rejecting the use of an unusual “Iqbal” hearing to determine the plausibility of her allegations....more

Kelley Drye & Warren LLP

Second Circuit Requires Defendants to Satisfy Twombly’s Plausibility Standard to Sustain Affirmative Defenses

On March 12, 2019, the Second Circuit Court of Appeals issued an Opinion in GEOMC Co. v. Calmare Therapeutics Inc., 918 F.3d 92, which clarifies the previously amorphous standard for pleading affirmative defenses. The...more

Smith Debnam Narron Drake Saintsing & Myers,...

Back to Basics: District Court Opinion Serves as a Reminder that Minimum Pleading Standards Must be Met to Stave off Dismissal

A recent District Court decision serves as a reminder to both Plaintiffs and Defendants to properly scrutinize a complaint for well-pleaded factual allegations. In Walker v. Lyons, Doughty & Veldhuis, P.C., et. al, No....more

Goodwin

Southern District of California Dismisses TCPA Case For Failure to Plead ATDS Element

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On January 16, 2019, the Southern District of California dismissed a Telephone Consumer Protection Act (TCPA) claim against Lyft because the plaintiff failed to support the automatic telephone dialing system (ATDS) element of...more

Dorsey & Whitney LLP

Twombly at the TTAB – Abandonment Allegations Found Sufficient

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The U.S. Supreme Court’s blockbuster rulings in Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal represented a major shift in federal pleading standards. Resolution of motions to dismiss frequently turns on whether a...more

Jones Day

Pleading Patent Infringement in the United States: Evolving Standards

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The Situation: Federal Rule of Civil Procedure 84, which permitted U.S. patent-infringement lawsuits to proceed on very general allegations, was withdrawn three years ago. Subsequent court decisions have considered how much...more

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