Precedential Federal Circuit Opinions
1. NIAZI LICENSING CORPORATION v. ST. JUDE MEDICAL S.C., INC. [OPINION] (2021-1864, 4/11/22) (Taranto, Bryson, Stoll)
Stoll, J. Affirming sanctions that excluded portions of patent owner's expert reports due to failure to disclose predicate facts during discovery. Also affirming sanction that excluded portions of patent owner's damages report because it was unreliable. Also affirming monetary sanctions order awarding costs and attorney fees associated with a motion to strike material that violated the district court's prior exclusion order. Also reversing determination of indefiniteness for claims related to catheter for treating heart failure. The district court found the claim terms "resilient" and "pliable" to be indefinite, but the Court disagreed finding that "those terms are broad, but they are not uncertain." Also affirming summary judgement of no induced infringement of a method claim because the defendant's instructions for using its product recited performing steps in an order different than the order required by the claim.
2. APPLE INC. v. ZIPIT WIRELESS, INC. [OPINION] (2021-1760, 4/18/22) (Hughes, Mayer, Stoll)
Stoll, J. Reversing dismissal of declaratory judgment action and remanding. The district court concluded that "it would be unreasonable to exercise jurisdiction over [defendant] under our court's precedent solely because [defendant's] contacts with California all related to the attempted resolution of the status of the patents-in-suit, i.e., 'for the purpose of warning against infringement.' [citation omitted]. This was error. As we explained most recently in Trimble, 'there is no general rule that demand letters can never create specific personal jurisdiction.'"
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