Correspondent
White House correspondent, covers patent, trade and regulatory news
The Federal Circuit affirmed the Patent Trial and Appeal Board's decision that patent claims covering semiconductor stacking methods were obvious. The court rejected Katana Silicon Technologies' argument that the claims required a pre-formed solid sheet, adopting the Board's broader construction of an adhesion layer.
The Federal Circuit dismissed an appeal as moot because the parties' settlement agreement functioned as a side bet rather than a genuine dispute. The court found that a potential $100 license fee reduction was insufficient to establish the Article III case or controversy required for judicial review.
The Federal Circuit denied a petition for a writ of mandamus seeking to overturn a district court order disqualifying patent counsel. The appellate court upheld the disqualification, finding that a third-party payment arrangement created an impermissible conflict of interest that materially limited the lawyers' independent judgment.
The Ninth Circuit denied petitions for panel and en banc rehearing, upholding the district court's summary judgment that the Bureau of Land Management lacked authority to conduct a land exchange involving Fort Hall Reservation lands. The court held that a specific 1900 statute governing these ceded lands prohibits disposal via the Federal Land Policy and Management Act because the earlier law's plain text bars such transfers.
The Ninth Circuit denied petitions for panel and en banc rehearing, leaving in place a ruling that the Bureau of Land Management lacked authority to conduct a land exchange involving Fort Hall Reservation ceded lands. The court held that a specific 1900 Act provision restricting disposal of these lands to certain enumerated laws supersedes the general disposal authorization found in the Federal Land Policy and Management Act of 1976.
The Fourth Circuit affirmed summary judgment for defendants regarding the Towner and Stone leases but vacated the ruling for the Hudson leases. The court held that the district court failed to apply West Virginia's 'first in time' rule to determine if a 1996 assignment extinguished the plaintiff's claimed interests in the Hudson properties.
The Ninth Circuit affirmed a Bankruptcy Appellate Panel ruling that creditors violated the bankruptcy discharge injunction by misapplying Chapter 13 plan payments. The court further held that emotional distress damages remain a potential remedy for such violations under traditional civil contempt principles.
The Ninth Circuit reversed and remanded a wage-and-hour judgment against Jack in the Box, holding that willfulness of overdeductions requires a factual trial and that employers must pay for shortened meal periods under Oregon law. The panel also ruled that shoe deductions were not automatically for the employee's benefit and remanded for class certification reconsideration on unpaid breaks and shoe claims.
The Eleventh Circuit vacated a dismissal based on the Rooker-Feldman doctrine, ruling that the district court should have dismissed the plaintiff's complaint for being an unintelligible shotgun pleading. The appellate court held that the plaintiff's failure to comply with prior repleader orders required dismissal under Rule 12(b)(6) for failure to state a claim rather than for lack of subject matter jurisdiction.
The Sixth Circuit vacated a district court order deferring summary judgment and ordering further discovery in a qualified immunity case. The appellate court held that the district court failed to properly analyze whether discovery was necessary to resolve genuine disputes of material fact before allowing it to proceed.
