Background
Linfo IP, LLC sued Trustpilot, Inc. for patent infringement regarding U.S. Patent No. nine zero nine two four two eight. The district court dismissed the suit, finding the patent claims invalid under the Alice framework. While the appeal was pending, the parties entered a settlement agreement granting Trustpilot a license to the patent.
The court’s reasoning
The court determined that Article III jurisdiction requires a live case or controversy. The settlement agreement granted Trustpilot a worldwide license to the patent and required the dismissal of the underlying lawsuit if it resumed. The court found that the patent owner’s voluntary act of settling the claims mooted the appeal because the opposing party no longer had a stake in the outcome.
What it means going forward
Patent owners must ensure that settlement agreements do not inadvertently resolve all claims before appealing a district court’s invalidity ruling, or risk having their appeals dismissed as moot.