Deference to government powerSkepticism of government power
Dismisses criminal antitrust charges by applying a statutory exemption that limits government enforcement power while upholding other government actions when facts support reasonableness. Brooks v. United States ↗ United States v. Tucor Internati… ↗
The case involved defendant Ethan Berry, who was indicted for Social Security representative fraud under 42 U.S.C. § 408(a)(5) for allegedly converting approximately $53,541 in child insurance benefits intended for his minor son to his own use between 2005 and 2006. Berry moved to dismiss the indictment, arguing that he lacked fair notice that his conduct, particularly regarding retroactive lump-sum payments, was criminal, and that the rule of lenity should apply. The court denied the motion, holding that the statute clearly proscribes the misuse of benefits by representative payees, prior cases support such prosecutions, and there was no ambiguity warranting dismissal or application of lenity.
The case concerned plaintiff Frank Shum's claims against Intel and related parties arising from the dissolution of Radiance Design, Inc., a company co-founded by Shum and Jean-Marc Verdiell to develop optoelectronic technology. Shum alleged he was improperly excluded as an inventor on seven patents later assigned to LightLogic and acquired by Intel, and asserted state-law claims including intentional misrepresentation, breach of contract, and unjust enrichment based on events surrounding the withdrawal of an initial patent application and the formation of LightLogic. The court granted defendants' renewed motion for judgment as a matter of law on all state-law claims, finding insufficient evidence to support them. On inventorship, the court entered judgment consistent with the jury verdict that Shum was a co-inventor on specified claims of five patents, granted JMOL denying co-inventorship on particular claims of two other patents, and noted Shum had withdrawn his claim as to one patent.
This case concerns a patent infringement dispute involving U.S. Patent No. 5,211,311, owned by DSU Medical, which covers needle guard devices designed to prevent accidental needle sticks in medical procedures. The court conducted a Daubert hearing to evaluate the admissibility of expert testimony from Dr. Robert Degnan regarding hypothetical lost profits damages based on a reconstructed contract between Medisystems and Fresenius, as well as damages calculations tied to sales of the WingEater needle guard. The court ruled that Dr. Degnan's testimony on the hypothetical contract and related damages was inadmissible because it relied on speculation without sound economic proof of market conditions or feasible contract terms. The court further held that sales of the WingEater, an acceptable noninfringing substitute, could not form the basis for compensable patent damages.
The case involved a dispute between two companies selling protocol analyzers for testing computer device compatibility, with CATC alleging that Catalyst's graphical user interface infringed CATC's trademark, trade dress, and copyright in its own GUI design, along with related unfair competition claims under federal and state law. After a jury trial, the jury found for CATC on the trademark infringement, willfulness, and unfair competition claims (awarding damages including lost profits), but for Catalyst on the trade dress and copyright claims. The court granted Catalyst's motion for a new trial on the trademark, willfulness, and unfair competition claims, as well as on the trade dress and copyright claims. The core reasoning was that the jury's verdict was against the clear weight of the evidence, warranting a new trial under Federal Rule of Civil Procedure 59(a) to avoid a miscarriage of justice, after the court weighed the evidence and assessed witness credibility.
This case involves a patent infringement dispute in which E-Pass Technologies sued 3Com, alleging that the Palm VII and VIIx devices infringed U.S. Patent No. 5,276,311, which covers a method and device for an electronic multi-function card that stores data from multiple credit, check, or identity cards. The court had previously construed the patent to require the device to have the width and outer dimensions of a standard credit card. On summary judgment, the court found no literal infringement because the Palm devices measure 3.25 by 5.25 by 0.75 inches, far exceeding credit-card size. It also rejected infringement under the doctrine of equivalents, holding that the size difference was substantial, that equivalence would vitiate the patent's core size limitation tied to its purpose of card substitutability, and that the accused products could not function as the patent intended.
This case is a patent infringement dispute concerning U.S. Patent No. 5,276,311, which describes a method and electronic multi-function card for storing data from multiple individual cards such as credit or identity cards, with access protected by a user-entered secret code. The court conducted claim construction as the first step in infringement analysis, focusing on the meaning of terms including 'activated' and 'entering said secret code into the multi-function card to activate the same.' Relying on the patent's intrinsic evidence such as the specification and claims, the court construed 'activated' to mean the state achieved when the user enters the secret code, enabling access to stored data sets like logos, photos, or signatures; it rejected interpretations tying activation strictly to powering on the device before code entry. The decision draws from the patent's descriptions linking activation to the initial loading process and visibility of data after code input.
