Our weekly SoCal IP Institute meeting on Monday, March 11, 2013 will be a discussion of two patent cases from the Federal Circuit. Brief synopses of the cases appear below.
Radio Systems Corp v. Lalor, Case No. 2012-1233 (Fed. Cir. March 6, 2013) (available here).
The Federal Circuit affirmed in part the district court’s decision that the plaintiffs did not infringe two of defendant’s patents. The patents were on improvements to electronic animal collars. The court held that district court decision is: 1) affirmed in part as to the judgment of non-infringement for GS-011, FieldPro, and SD-1825 collars, where the district court correctly construed the claim terms “electrode base” and “inside surface,” and correctly applied its constructions to these accused collars, 2) affirmed in part, where the district court did not abuse its discretion in concluding that equitable estoppel applied to defendant’s ’014 patent infringement allegations on the UltraSmart collar against both plaintiff Innotek and its successor-in-interest, plaintiff Radio Systems; but 3) reversed in part and remanded, as to the ’082 patent, where the district court abused its discretion by granting summary judgment of non-infringement for the UltraSmart collar on the basis of equitable estoppel.
Move, Inc. v. Real Estate Alliance Ltd., Case No. 12-1342 (Fed. Cir. March 4, 2013) (available here).
Summary judgment that plaintiff did not infringe claim 1 of defendant’s ’989 patent related to methods for locating available real estate properties using a zoom-enabled map on a computer, is vacated and remanded for a determination whether plaintiff is liable for indirect infringement, where the district court: 1) did not err by finding no genuine issue of material fact that plaintiff is not liable for direct infringement of claim 1 of the ’989 patent; but, 2) legally erred by not analyzing inducement under 35 U.S.C. 271(b); and 3) failed to conduct an indirect infringement analysis and did not determine whether a genuine issue of material fact existed as to the performance of all the claim steps, whether by one entity or several.
All are invited to join us in our discussion during the SoCal IP Institute meeting on Monday, March 11, 2013 at Noon in our Westlake Village office. This activity is approved for 1 hour of MCLE credit. If you will be joining us, please RSVP to Noelle Attalla by 9 am Monday morning.