Appellate Impacts
Recent federal appellate opinions with significant business impact. Covering securities, antitrust, labor & employment, intellectual property, arbitration, class actions, and bankruptcy. Court badges link to the full opinion on CourtListener.
No. 25-1045
Whether a jury verdict form that uses a single infringement question covering all asserted patents is reversible error, and whether the district court properly assessed patent eligibility under § 101 for building automation system patents.
The Federal Circuit vacated the $11.5 million infringement and damages judgments and remanded for a new trial, finding that the verdict form's single question on infringement for all asserted patents was deficient because it did not allow identification of which specific patents were infringed. The court affirmed that certain patents were not directed to abstract ideas under § 101 but remanded for further analysis under Alice step two for one patent.
Favorable to Business
Accused infringers benefit from the requirement that verdict forms identify which specific patents are infringed, preventing overbroad judgments based on aggregated infringement findings across multiple patents.
Risk for Business
Patent holders must ensure that verdict forms and trial procedures allow patent-by-patent infringement determinations, increasing trial complexity and risk of remand even after favorable jury verdicts.
No. 24-1730
Whether patent claims directed to automated farming data collection devices are patent-ineligible under 35 U.S.C. § 101, and whether the district court erred in finding the case was not exceptional under 35 U.S.C. § 285.
The Federal Circuit affirmed that patent claims directed to relay devices for tracking farming operations were patent-ineligible under § 101, finding they were directed to the abstract idea of collecting, processing, and sharing farming data using conventional computer components. The court vacated the district court's determination that the case was not exceptional and remanded for reconsideration of an attorneys' fees award under § 285.
Favorable to Business
Technology companies in the agricultural sector benefit from the invalidation of broad patents claiming conventional data collection methods, reducing litigation risk from patent assertion entities.
Risk for Business
Patent holders in the AgTech space face increased difficulty protecting software-implemented farming data systems under § 101, and the remand on exceptionality signals potential fee-shifting exposure for asserting ineligible patents.
No. 25-1807
Whether the statute of limitations under the Defend Trade Secrets Act had expired before Insulet brought its trade secret misappropriation claim against EOFlow relating to insulin patch pump technology.
The Federal Circuit reversed the district court's denial of JMOL, holding that Insulet's DTSA claim was time-barred. The court found that Insulet knew or should have known of the misappropriation more than three years before filing suit, based on evidence of former employees sharing CAD files and proprietary information with EOFlow. This decision vacated the damages judgment and permanent injunction.
Favorable to Business
Companies accused of trade secret misappropriation benefit from strict enforcement of the DTSA's three-year statute of limitations, providing a clear defense when the plaintiff delayed filing suit despite having knowledge of the alleged misappropriation.
Risk for Business
Trade secret owners must act promptly upon discovering or having reason to discover misappropriation; delay in filing suit—even while investigating the full scope of harm—risks losing the ability to pursue federal trade secret claims entirely.
No. 24-1140
Whether the district court erred in excluding Versata's trade secret damages expert testimony and in its assessment of damages for trade secret misappropriation under the DTSA and MUTSA, and whether the jury's breach of contract award should be reinstated.
The Federal Circuit vacated the trade secret damages judgment and remanded for a new trial, instructing the district court to reconsider two previously excluded damages models. The court also reversed the district court's judgment on breach of contract damages and reinstated the jury's award. The court affirmed liability for trade secret misappropriation relating to Ford's development of competing software while licensing Versata's technology.
Favorable to Business
Trade secret owners benefit from expanded consideration of damages models, including unjust enrichment theories, and from the reinstatement of jury-determined contract damages, strengthening remedies for misappropriation by licensees.
Risk for Business
Companies that develop competing products after licensing technology face heightened exposure to trade secret misappropriation liability and damages, even when the licensing relationship has ended.
No. 25-1317
Whether a patent owner that licenses exclusive commercialization rights but retains the right to sue third parties for infringement has sufficient constitutional standing to bring an infringement suit.
The Federal Circuit reversed the district court's dismissal for lack of standing, holding that a patent owner who retains exclusionary rights—including the right to independently sue for infringement—possesses a sufficient injury in fact to satisfy Article III standing, even after granting an exclusive license. This clarifies the boundaries of patent standing when rights are split between licensor and licensee.
Favorable to Business
Patent owners structuring license agreements can retain standing to enforce patents by preserving the right to sue for infringement, providing flexibility in licensing arrangements and ensuring continued ability to protect patent portfolios.
Risk for Business
Accused infringers may face suits from both licensors and licensees under shared enforcement provisions, increasing litigation exposure and complicating settlement negotiations.
No. 24-2089
Whether a district court may dismiss a patent infringement complaint on the pleadings based on obviousness grounds asserted in a prior IPR against related claims, and whether the resulting attorneys' fees award under § 285 and sanctions under § 1927 were warranted.
The Federal Circuit affirmed the dismissal of a patent infringement complaint where remaining claims survived IPR but were found invalid on the same obviousness grounds applied to canceled claims. However, the court reversed the § 285 exceptional-case fee award and § 1927 sanctions against counsel, finding that asserting surviving patent claims did not rise to the level of exceptionality or bad faith required for fee-shifting and sanctions.
Favorable to Business
Patent litigants and their counsel benefit from the reversal of fee awards and sanctions, confirming that asserting claims that survived IPR—even if ultimately found invalid—does not automatically constitute bad faith or exceptional conduct.
Risk for Business
Patent holders face increased risk of early dismissal when asserting claims closely related to those invalidated in IPR proceedings, as courts may apply the same invalidity reasoning to surviving claims at the pleading stage.
No. 24-1236
Whether a non-party to district court patent litigation may file IPR petitions challenging the same patents on the same filing deadline as the sued party, and whether the Board's obviousness determination was supported by substantial evidence.
The Federal Circuit vacated the Board's obviousness determination regarding FedEx's sensor-based logistics patent and remanded for further proceedings. The court also addressed the practice of third parties filing IPR petitions timed to the statutory deadline of a party actually sued for infringement, declining to review the Board's denial of FedEx's motion to terminate but signaling scrutiny of such tactics.
Favorable to Business
Patent holders benefit from the vacatur of the obviousness finding, preserving patent rights in sensor-based logistics technology. The decision also signals judicial attention to coordinated IPR filing strategies by non-parties.
Risk for Business
Companies using IPR as a defensive strategy face uncertainty about the viability of coordinated third-party petitions timed to another party's statutory deadline, potentially limiting strategic options for patent challenges.
No. 24-1822
Whether patents claiming non-uniform constellations for digital communication systems are patent-eligible under 35 U.S.C. § 101, and whether the district court properly denied JMOL on infringement and damages.
The Federal Circuit vacated the summary judgment of eligibility for certain patent claims directed to non-uniform constellations used in communication systems, finding that the district court did not adequately analyze whether the claims were directed to abstract ideas under Alice step one. The court affirmed eligibility for other claims and affirmed the denial of JMOL on infringement and damages, including a willful infringement finding against LG.
Favorable to Business
Companies defending against patent assertions benefit from more rigorous application of Alice step one analysis, potentially invalidating broad claims directed to mathematical optimization concepts in communications standards.
Risk for Business
Patent holders asserting claims related to standards-essential technology face increased uncertainty regarding eligibility under § 101, particularly where claims may be characterized as directed to mathematical relationships or optimization.
No. 25-1580
Whether there was legally sufficient evidence to support the jury's finding that the asserted information constituted protectable trade secrets under California law, and whether the inventorship of related patents should be corrected.
The Federal Circuit reversed the district court's denial of JMOL on trade secret misappropriation claims, finding insufficient evidence that the plaintiff's asserted trade secrets were protectable because the underlying ideas were generally known in the field. The court also reversed on patent invalidity, holding that since the allegedly misappropriated ideas were generally known, they could not constitute an inventive contribution for inventorship purposes. The counterfeiting claim and associated damages were affirmed.
Favorable to Business
Defendants in trade secret cases benefit from rigorous scrutiny of whether asserted trade secrets are truly novel and not generally known, providing a strong defense when plaintiffs claim broadly known concepts as proprietary.
Risk for Business
Companies relying on trade secret protection must clearly demonstrate that their claimed secrets derive independent economic value from not being generally known; failure to do so risks losing both trade secret and related patent claims simultaneously.
No. 24-1094
Whether the district court erred in granting judgment as a matter of law that Teva's anti-CGRP antibody headache treatment patents were invalid for failure to satisfy the written-description and enablement requirements of 35 U.S.C. § 112.
The Federal Circuit reversed the district court's JMOL of invalidity, reinstating the jury verdict that Lilly willfully infringed Teva's headache patents covering humanized anti-CGRP antagonist antibodies. The court found that the patents' disclosure of one humanized antibody, combined with known methods of humanization and prior art murine antibodies, was sufficient to satisfy written description and enablement for the genus claims.
Favorable to Business
Pharmaceutical and biotech companies benefit from a more permissive standard for genus claims where the specification discloses representative species and references known techniques, preserving broad patent protection for biologic drug classes.
Risk for Business
Generic and biosimilar developers face strengthened patent barriers for biologic treatments, as genus claims covering classes of antibodies may be harder to invalidate under § 112.
No. 24-1772
Whether the district court erred in granting summary judgment of noninfringement based on extraterritoriality and in striking damages expert theories for inadequate disclosure in contentions.
The Federal Circuit reversed in part the summary judgment of noninfringement of the '836 patent, finding that genuine issues of material fact remained regarding whether the accused multicore processor technology practiced the claimed methods domestically. The court affirmed the district court's decision striking certain damages theories for failure to adequately disclose them in damages contentions, reinforcing disclosure requirements in patent litigation.
Favorable to Business
Patent holders benefit from the court's rejection of broad extraterritoriality defenses where there is evidence that claimed methods are practiced within the United States, preserving enforcement rights against technology companies with global operations.
Risk for Business
Technology companies face increased risk that extraterritoriality arguments will not shield them from infringement liability, and must ensure robust compliance with damages contention disclosure requirements to preserve expert testimony.
No. 24-1761
Whether a Rule 30(b)(6) corporate representative may testify outside personal knowledge for purposes of summary judgment, and whether the on-sale bar under pre-AIA 35 U.S.C. § 102(b) requires express disclosure of a device's functionality in the sale.
The Federal Circuit affirmed summary judgment of invalidity under the on-sale bar, holding that Rule 30(b)(6) testimony from a corporate representative is admissible at summary judgment even if the witness lacks personal knowledge, and rejecting the argument that the on-sale bar requires express disclosure of the prior art device's internal functionality at the time of sale. The court confirmed that a commercial sale of a device embodying all claim limitations triggers the bar regardless of whether the buyer knew the device's internal workings.
Favorable to Business
Accused infringers and patent challengers benefit from the broad applicability of the on-sale bar and the ability to use 30(b)(6) testimony to establish prior art sales, making it easier to invalidate patents based on pre-critical-date commercial activity.
Risk for Business
Patent holders face heightened invalidation risk from prior sales of products embodying claimed inventions, even when the inventive functionality was not publicly disclosed or understood at the time of sale.
No. 26-1026
Whether an ITC respondent may obtain a mandatory stay under 28 U.S.C. § 1659(a)(2) by voluntarily dismissing and refiling a declaratory judgment action after missing the statutory deadline for seeking a stay in the original action.
The Federal Circuit held that an ITC respondent cannot circumvent the mandatory stay deadline under § 1659(a)(2) by dismissing and refiling a parallel district court declaratory judgment action. The court found that allowing such a tactic would render the statute's time limits meaningless and undermine the congressional scheme balancing ITC proceedings with district court litigation.
Favorable to Business
ITC complainants (patent holders) benefit from certainty that respondents cannot manipulate litigation timing to delay or stay parallel district court proceedings after missing statutory deadlines.
Risk for Business
Companies facing both ITC investigations and parallel district court patent litigation must strictly comply with the 30-day deadline for requesting a mandatory stay; failure to do so forecloses any future attempt to obtain the stay through refiling.
No. 24-1757
Whether the district court properly approved a $125 million class action settlement of claims that the federal judiciary overcharged PACER users, including the reasonableness of attorneys' fees and incentive awards to class representatives.
The Federal Circuit affirmed approval of a $125 million nationwide class action settlement resolving claims that the federal judiciary exceeded its statutory authority by using PACER fees to fund expenses unrelated to the PACER system. The court upheld the settlement terms, attorneys' fees, and incentive awards to the three nonprofit class representatives, noting that hundreds of thousands of PACER users would receive full or substantial reimbursement.
Favorable to Business
The settlement provides direct financial benefit to businesses and law firms that are heavy PACER users, establishing that government fee programs must be tethered to their statutory authorization and providing a reimbursement mechanism for overcharges.
Risk for Business
None significant.
No. 24-1285
Whether the ITC correctly determined that Apple's importation and sale of Apple Watch models with blood oxygen measurement functionality violated Section 337 of the Tariff Act by infringing Masimo's patents.
The Federal Circuit affirmed the ITC's finding that Apple violated Section 337 by importing and selling Apple Watches that infringed Masimo's patents covering wearable blood oxygen measurement technology. The court upheld the Commission's domestic industry determination, validity rulings, and infringement findings, sustaining the limited exclusion order barring importation of infringing Apple Watch models.
Favorable to Business
Patent holders benefit from the affirmation that the ITC remains an effective venue for enforcing patent rights against large technology companies importing infringing products, with exclusion orders providing powerful remedies.
Risk for Business
Major technology companies incorporating patented sensor technology into consumer products face significant commercial disruption from ITC exclusion orders that can block importation of flagship product lines.
Last updated 2026-06-11 · Source: CourtListener · Analysis: Claude AI