Correspondent
White House correspondent, covers patent, trade and regulatory news
The United States Court of Appeals for the Eleventh Circuit dismissed an appeal filed by Christopher Whitman challenging a district court order regarding federal tax liens. The appellate court ruled that it lacked jurisdiction because the district court had not yet entered a final order of sale to foreclose on the properties.
The United States Court of Appeals for the Federal Circuit affirmed the district court's denial of a motion for judgment as a matter of law regarding patent infringement and invalidity findings in a dispute over DSL technology patents.
The Ninth Circuit affirmed the dismissal of a developer's federal constitutional claims, holding that the plaintiff failed to allege a constitutionally protected property interest in the disputed land or contractual payments. The court reasoned that the plaintiff conveyed legal title to the property and that the contract language did not create a legitimate claim of entitlement to payment for a specific number of lots.
The Ninth Circuit affirmed the dismissal of Arthur Tsatryan's federal claims, ruling that his lawsuit functioned as an impermissible de facto appeal of prior state divorce judgments. The court held that the Rooker-Feldman doctrine barred federal review because the claims were inextricably intertwined with state court orders and lacked sufficient allegations of extrinsic fraud.
The Ninth Circuit affirmed the dismissal of Teri Sahm's foreclosure challenge, ruling that her complaint failed to state a claim due to a lack of factual allegations linking defendants to harm. The court upheld the district court's findings on preclusion, recusal, and vexatious litigant status, leaving the dismissal and restrictions on future filings in place.
The United States Court of Appeals for the Fourth Circuit denied a petition for a writ of mandamus filed by Lisa Richardson Henderson. The court held that the relief sought was not available through this extraordinary remedy.
The United States Court of Appeals for the Federal Circuit affirmed a Patent Trial and Appeal Board decision finding specific patent claims unpatentable for obviousness. The court held that substantial evidence supported the Board's findings regarding prior art references and the motivation to combine them.
The Federal Circuit affirmed the Patent Trial and Appeal Board's obviousness rejections for most claims of a network-threat detection patent but reversed its finding for two specific claims. The court held that the Board failed to provide substantial evidence that a skilled artisan would have been motivated to combine prior art references to render claims 4 and 14 obvious.
The Federal Circuit affirmed the International Trade Commission's finding that no Section 337 violation occurred, upholding the termination of the investigation. The court held that substantial evidence supported the conclusion that Centripetal's products failed to meet the technical requirements of the asserted patent claims.
The Federal Circuit affirmed the district court's ruling that specific augmented reality patent claims are invalid under 35 U.S.C. § 101 as abstract ideas. The court held that the patents merely recite generic computer components performing conventional location-based filtering without an inventive concept.
