September 28, 2007

I will periodically post case citations from the Federal Circuit along with the date of the opinion/order and a brief list of the legal topics discussed therein (specifically those with additional embedded case law citations). My goal is to post new cases on a weekly basis. This posting covers the sole patent case that was appealed from the district court level and decided by the Federal Circuit during the 35th calendar week of 2007. All opinions are precedential unless otherwise indicated.

Egyptian Goddess, Inc., et al. v. Swisa, Inc., et al. (08/29/2007): appeal of final judgment granting summary judgment of noninfringement of design patent (affirmed); discussion of design patent related to an ornamental design for a nail buffer (U.S. Patent No. D467,389, entitled “Nail buffer”); there are two distinct requirements for establishing design patent infringement: (1) “[t]he first, called the ordinary observer test, requires that “in the eye of an ordinary observer, giving such attention as a purchaser usually gives, [the] two designs are substantially the same . . . the resemblance is such as to deceive such an observer, inducing him to purchase one supposing it to be the other”, and (2) “[t]he second, called the point of novelty test, requires that “no matter how similar two items look, ‘the accused device must appropriate the novelty in the patented device which distinguishes it from the prior art’”; “[f]or a combination of individually known design elements to constitute a point of novelty, the combination must be a non-trivial advance over the prior art”; the district court “properly” determined that “no reasonable jury could conclude that the point of novelty proffered by EGI is a non-trivial advance over the prior art”; because the district court properly determined that there is no genuine issue of material fact as to whether the alleged infringing product appropriates the point of novelty of the claimed design, the judgment was affirmed

September 27, 2007

By David Quick

Footnote eight in Verizon Services Corp. v. Vonage Holdings Corp. (LINK, Fed. Cir. September 26, 2007) should serve as a warning to any patent prosecutor who continues to use the term "invention" in a patent specification. The safest practice, as has been adopted by many, appears to be totally avoiding the use of the term "invention" in a patent specification in any sentence that includes limiting language relating to a later claimed element.

Many patent prosecutors have completely avoided the use of the term "invention" in any patent application since Scimed Life Sys., Inc. v. Advanced Cardiovascular Sys., Inc., 242 F.3d 1337, 1343 (Fed. Cir. 2001) was decided for fear that limitations in the specification might be read into the subsequently issued claims. Other patent prosecutors, having read the Scimed decision in its entirety and having noticed the applicant's emphasis on the essential nature to the invention of the limitations read into the claims in that case, have sought only to limit their unrestricted usage of the term "invention" in patent applications. Such practitioners have assumed that by using the restrictive phrases "aspect of the invention" or "one embodiment of the present invention" prior to describing a limitation that is not recited in a claim, that they can avoid having that limitation read into the claim term. Under at least certain circumstances, this approach may not be effective. The CAFC in Verizon Services Corp. in interpreting the scope of the claims 1 and 6-8 in U.S. Patent No. 6,359,880 stated:

“Vonage challenges the district court’s construction of the term “localized wireless gateway system” of asserted claims 1 and 6-8 of the ’880 patent (the same term pertinent to the “few feet” limitation) on the ground that the district court erred in failing to require that the patented gateway system “compress[]/decompress[] and packetiz[e] voice signals.” Appellants’ Bf. at 26, n. 7. We agree. The “Disclosure of the Invention” section of the ’880 patent begins with a description of the gateway system of the “present invention.” ’880 patent col.4 ll.1-6. In the course of describing the “present invention,” the specification then states that “[t]he gateway compresses and decompresses voice frequency communication signals and sends and receives the compressed signals in packet form via the network.” Id. ll.12-15. When a patent thus describes the features of the “present invention” as a whole, this description limits the scope of the invention. Honeywell Int’l, Inc. v. ITT Indus., 452 F.3d 1312, 1318-19 (Fed. Cir. 2006); Scimed Life Sys., Inc. v. Advanced Cardiovascular Sys., Inc., 242 F.3d 1337, 1343 (Fed. Cir. 2001) (“[T]he characterization of the coaxial configuration as part of the ‘present invention’ is strong evidence that the claims should not be read to encompass the opposite structure.”); see also Andersen Corp. v. Fiber Composites, LLC, 474 F3d 1361, 1368 (Fed. Cir. 2007) (specification’s description of a “critical element” found limiting).8 Thus the term “localized wireless gateway system” must be limited to one performing compression and packetization functions at the gateway.”

Nothing in the above language should serve as a complete surprise to any practitioner who has followed the claim scope case law since Scimed. The patent prosecutor of the '808 patent was obviously not sufficiently clairvoyant when drafting the application in 1999 to limit the term "invention" in the manner that a proper interpretation of Scimed (decided two years later) would justify. However, footnote 8 in Verizon Services Corp., should cause prosecutors to rethink whether the restrictions they have been placing on the use of the term "invention" in recent years is adequate. In footnote 8, the CAFC stated:

“8 Verizon argues that the “present invention” language is not significant in this case because the specification merely refers to “one aspect” of “the present invention.” But that “aspect” is the “localized wireless gateway system,” the very claim term that is at issue here. See ’880 patent col.4 ll.6-7 (“Thus, in one aspect, the present invention relates to a localized wireless gateway system.”).”

In view of the dicta in footnote 8 of Verizon Services Corp., and if you are a patent practitioner, you may wish to carefully consider whether to use the term “invention” in any patent application.

David Quick is a patent attorney with Ice Miller LLP focusing his efforts on patent prosecution and general intellectual property matters.

Verizon v. Vonage Opinion: LINK
U.S. Patent No. 6,359,880: LINK
Scimed v. Advanced Cardiovascular Sys. Opinion.: LINK

September 26, 2007

The USPTO recently announced that its newest exhibit, entitled “Tech Art: The Photography of Vince Gonzales”, will open this week in the Atrium of the main USPTO facility in Alexandria, Virginia. This exhibit, comprising 37 photographs uncovering “dramatic shapes, distinctive textures and colors, [and] hidden details of craftsmanship and design,” ran earlier this year on the west coast at the Academy of Motion Picture Arts and Sciences Pickford Center for Motion Picture Study in Hollywood. According to the USPTO (announcement link below), “[t]he exhibit also provides a great compliment to the USPTO’s current exhibit, “Art of Invention – Invention of Art.” The exhibit includes 70 works of art that have emerged from inventions, patents and trademarks.” The Vince Gonzales exhibit will be available to the public through November 18th.

USPTO Announcement: LINK

September 24, 2007

The USPTO recently announced that it will be hosting a “National Trademark Expo” in April “to engage the public’s interest and educate consumers about the vital role trademarks play in the global economy.” This Expo will be held from April 10th through the 12th at the USPTO’s Alexandria, VA, facility, and will showcase companies with registered trademarks. Any company with a registered trademark may apply for a space at the Expo (application link below), and potential exhibitors will be evaluated on three categories, namely brand recognition, educational value of the proposed exhibit, and category diversity. Details on these three categories, and a date when a company may learn whether or not it was selected for the Expo, may be found at the USPTO announcement link below.

USPTO Announcement: LINK
USPTO Exhibit Application: LINK

September 20, 2007

The USPTO recently announced that has begun a collaborative effort with the Swedish Patent and Registration Office (PRV) “to test the feasibility of the PRV performing search and examination services for the USPTO on international applications filed with the USPTO under the Patent Cooperation Treaty (PCT).” This project is specifically geared toward reducing the backlog of patent applications at the USPTO, noting that the USPTO has been averaging over 400,000 national applications and 50,000 PCT applications per year, and further noting that approximately 750,000 patent applications are “currently in the pipeline.” This pilot project will start with 50 PCT Chapter I applications, and plans to expand if the PRV meets the USPTO’s standards for quality and accuracy. According to Lars Bj√∂rklund, acting Director General of the PRV, “The PRV is a competent PCT Authority since the start of the PCT system in 1978 and we have a long experience of patent search and examination,” and “We look forward to cooperating with the USPTO and thereby also taking responsibility to support and maintain the functionality of the PCT system.”

USPTO Announcement: LINK
Swedish Patent and Registration Office (PRV) Website: LINK

September 19, 2007

On Tuesday, the USPTO announced that effective January 1, 2008, it will be changing how it distributes bulk data and the way it charges for the data. According to the USPTO, it “will change its distribution model for Trademark bulk data by eliminating all charges for downloadable daily files and reducing the price of retrospective data distributed on optical disc.” Some of the bulk data will be available for free that was previously only available by a subscription will consist of a number of Trademark Data/XML files, including the Trademark Daily Applications file (containing text data of applications filed, published for opposition, registrations issued, registrations renewed, registrations cancelled, registrations amended or corrected, registrations issued new certificates), the Trademark Daily Assignments file (containing text data of ownership transfers), and the Trademark Daily TTAB file (containing text data of Trademark Trial and Appeals Board adversary proceedings). In addition, the Trademark Daily Application Image 24 Hour Box (containing images processed through the Trademark Image Capture and Retrieval System (TICRS) in a 24-hour Period, in JPEG (black and white, grey-scale, or color)) and TIFF (black and white) formats) will be available for free starting January 1st. As mentioned above, optical discs will still be available for a number of Trademark Retrospective/XML files (trademark applications, assignments, and the TTAB files), but the cost will be lower, and the discs may still be purchased at the link below.

USPTO Announcement: LINK
Trademark Retrospective/XML File Website: LINK
Full USPTO 2007 Products & Services Catalog (PDF): LINK

September 17, 2007

In a recent filing in the U.S. District Court for the Western District of Texas, Austin Division, the Lance Armstrong Foundation alleges that Chris Ohman and Animal Charity Collar Group (dba infringe on its trademark rights to LIVESTRONG. The complaint, as reported by The Smoking Gun (link below), alleges that starting in June 2005, the defendants marketed and offered for sale “yellow pet collars made of a silicone-like material bearing the words BARKSTRONG or PURRSTRONG” and “subsequently began selling other products featuring these words or similar wording…” The defendants allegedly began using those two marks, and also used CAN YOUR DOG BARKSTRONG AND CAN YOUR CAT PURRSTRONG even after the defendants pursued a “business deal” with plaintiff for which the plaintiff denied based upon the defendants’ lack of business experience in this area. The suit alleges trademark and trade dress infringement, alleging that the “BARKSTRONG Marks are confusingly similar to, and are likely to cause confusion, mistake or deception, as to origin, source, sponsorship, or affiliation” with the plaintiff. Images of the collars at issue are also provided in The Smoking Gun link below. It is noted that the Lance Armstrong Foundation has 11 pending U.S. trademark applications or registered U.S. trademarks, including U.S. Trademark Reg. No. 3,052,284 for LIVESTRONG in IC 014 (jewelry) and IC 036 (charitable fundraising services).

The Smoking Gun Article: LINK
U.S. Trademark Reg. No. 3,052,284: LINK
Lance Armstrong Foundation Website: LINK

September 14, 2007

According to The Smoking Gun (link below), attorneys for Paris Hilton have filed suit against Hallmark regarding a greeting card distributed by Hallmark with Paris’s likeness. The card (available at the first link below) shows a photograph of Paris’s head on a cartoon waitress body, handing a plate of hot food to a patron. The dialogue with the patron is as follows:

Paris: “Don’t touch that, it’s hot.”
Patron: “What’s hot?”
Paris: “That’s hot.”

The bottom of the card reads “Paris’s First Day as a Waitress.”

The lawsuit, naming Hallmark Cards and Does 1-10 as defendants, alleges commercial appropriation of identity (under the California Civil Code), invasion of privacy, misappropriation of publicity, and false designation of origin under the Lanham Act (§ 43(a), 15 U.S.C. § 1125(a)). The complaint states that “Defendant has wrongfully utilized Plaintiff’s name and identity and, therefore, damaging her rights of privacy and publicity, her exclusive property rights and her personal rights in and to the use of her name and likeness.” Although the entire complaint is not available on The Smoking Gun, the damages sought at least for one cause of action (commercial appropriation) are “actual damages in an amount to be shown at trial, but not less than one hundred thousand dollars ($100,000.00).” Be sure to check out the last page of the article (last link below), which is an unidentified greeting card stating “The Really, Really, Really, Really, Simple Life” and, well, you’ll see the rest.

By way of background (not available at The Smoking Gun), Paris Hilton has filed thirty-six (36) U.S. trademark applications, three of which for “THAT’S HOT” (U.S. Trademark Application Nos. 76/604206, 76/615015, and 77/163240), and one of which (76/604206) issuing as U.S. Trademark Reg. No. 3,209,488.

The Smoking Gun Article & Greeting Card Image: LINK
Complaint (First Four Pages): LINK
Unidentified Greeting Card Image: LINK
U.S. Trademark Application No. 76/604206: LINK
U.S. Trademark Application No. 76/615015: LINK
U.S. Trademark Application No. 77/163240: LINK

September 13, 2007

I will periodically post case citations from the Federal Circuit along with the date of the opinion/order and a brief list of the legal topics discussed therein (specifically those with additional embedded case law citations). My goal is to post new cases on a weekly basis. This posting covers the three patent cases that were appealed from the district court level and decided by the Federal Circuit during the 34th calendar week of 2007. All opinions are precedential unless otherwise indicated.

In re Seagate Technology, LLC. (08/20/2007) (errata: LINK): please refer to Greg Duff’s summary of this case, entitled “Federal Circuit Clarifies Willfulness Standard” available here: LINK

Ormco Corporation, et al. v. Align Technology, Inc. (08/24/2007): appeal of grant of summary judgment that four patents in suit were not infringed and are invalid, with cross-appeal of grant of summary judgment of invalidity of certain claims of a fifth patent (affirmed-in-part and reversed-in-part); discussion of patents related to computer-aided design and manufacture of custom orthodontic appliances (U.S. Patent Nos. 5,447,432, 5,683,243, 6,244,861, 6,398,548 and 6,616,444); “[i]t is a bedrock principle of patent law that the claims of a patent define the invention to which the patentee is entitled the right to exclude”; “[w]hen the application of prosecution disclaimer involves statements from prosecution of a familial patent relating to the same subject matter as the claim language at issue in the patent being construed, those statements in the familial application are relevant in construing the claims at issue”; “[b]ecause the court correctly granted summary judgment as to some but not all of the claims of the Ormco patents, we affirm in part and reverse in part the judgment as to the Ormco patents … [and] [b]ecause the court correctly granted summary judgment of invalidity of the specified claims of the ’548 patent, we affirm that judgment”

Shum v. Intel Corporation, et al. (08/24/2007): appeal of decision dismissing plaintiff’s claims for correction of inventorship and several state law claims (vacated, reversed, and remanded); discussion of patent related to optoelectronic assemblies (U.S. Patent No. 5,977,567, entitled “Optoelectronic assembly and method of making the same”); “[a] correction for inventorship claim under [35 C.F.R.] section 256 creates a cause of action in federal courts that authorizes a district court to resolve inventorship disputes over issued patents”; “[w]ith regard to the correction of inventorship claim under § 256, “the critical question for joint conception is who conceived, as that term is used in the patent law, the subject matter of the claims at issue”; “[b]ecause we conclude that the district court erred in conducting a bench trial on the inventorship claim prior to a jury trial on the state law claims when there were common underlying factual issues, and erred in dismissing the unjust enrichment claim on the pleadings, we vacate, reverse, and remand”

September 11, 2007

The USPTO has announced that it will host several IP seminars this month:

September 12th: "The Cost of Counterfeiting and Piracy" – to be held from 11:30 – 2:00 at the IBC Bank, 130 E. Travis, 5th Floor Community Room, San Antonio, Texas. Speakers include Congressman Henry Cuellar, John Rodriguez of the USPTO, Salvador Behar of the Embassy of Mexico, A.J. Rodriguez of the San Antonio Hispanic Chamber of Commerce, and Chris Merida of the U.S. Chamber of Commerce.

September 14th: "Protecting Your Intellectual Property in the Global Marketplace" – to be held from 8:30 – 4:30 at the Doubletree Hotel & Executive Meeting Center, Portland-Lloyd Center, 1000 NE Multnomah, Portland, Oregon, and will and feature U.S. Representative Earl Blumenauer

September 14th-15th: "12th Annual Independent Inventors Conference" – to be held at North Carolina State University, College of Textiles, 100 Main Campus Drive, Raleigh, North Carolina. Speakers include Margaret J.A. Peterlin, Margaret Focarino, John Love, and a number of Supervisory Patent Examiners from the USPTO, as well as Michael Sykes, the 2007 Winner of the Modern Marvels Invent Now® Challenge competition.

September 19th-20th: "Conference on Protecting Your Intellectual Property in China and the Global Marketplace" – to be held at the Hyatt Regency Crown Center, 2345 McGee Street, Kansas City, Missouri. Over 20 speakers from the USPTO, U.S. industries, and U.S. and Chinese law firms are expected.

USPTO September 12th Seminar Announcement: LINK
September 12th Seminar Webpage: LINK
USPTO September 14th Seminar Announcement: LINK
September 14th Seminar Webpage: LINK
USPTO September 14th -15th Seminar Announcement: LINK
September 14th -15th Seminar Webpage: LINK
USPTO September 19th-20th Seminar Announcement: LINK
September 19th-20th Seminar Webpage: LINK

September 10, 2007

I will periodically post case citations from the Federal Circuit along with the date of the opinion/order and a brief list of the legal topics discussed therein (specifically those with additional embedded case law citations). My goal is to post new cases on a weekly basis. This posting covers the four patent cases that were appealed from the district court level and decided by the Federal Circuit during the 33rd calendar week of 2007. All opinions are precedential unless otherwise indicated.

Advanced Cardiovascular Systems v. Medtronic Vascular (08/13/2007, non-precedential) (order): motion by ACS to dismissal Medronic’s appeal as premature, which was opposed by Medtronic; original suit brought against Medtronic for patent infringement, and a jury found infringement and determined that the patents were not invalid, for which the district court entered a “judgment” in favor of ACS; Medtronic’s appeal deemed premature “because ACS's request for permanent injunctive relief in its complaint remains pending and thus the case is not final except for an accounting”; “If a case is not fully adjudicated as to all claims for all parties and there is no express determination that there is no just reason for delay or express direction for entry of judgment as to fewer than all of the parties or claims, there is no final decision under 28 U.S.C. § 1295 (a)(1) and therefore no jurisdiction”; order that ACS’s motion to dismiss is granted

Nisus Corporation v. Perma-Chink Systems, Inc. v. Teschner (08/13/2007, non-precedential): appeal of district court order characterized by Teschner as “adjudging [him] guilty of inequitable conduct” in the prosecution of a patent application”, and appeal of order denying Teschner’s motion to intervene in the underlying patent infringement action (first appeal dismissed for lack of jurisdiction, and second appeal affirmed); discussion of patent related to methods of treating trees with boron to prevent infestation (U.S. Patent No. 6,426,095, entitled “Methods and compositions for retarding and eradicating infestation in trees and tree derived products”); “an exception to that general rule [that nonparties may not appeal from judgments or other actions of a district court], a nonparty such as an attorney who is held in contempt or otherwise sanctioned by the court in the course of litigation may appeal from the order imposing sanctions, either immediately or as part of the final judgment in the underlying case”; “a court’s order that criticizes an attorney and that is intended to be “a formal judicial action” in a disciplinary proceeding is an appealable decision, but that other kinds of judicial criticisms of lawyers’ actions are not reviewable”; “we hold that absent a court’s invocation of its authority to punish persons before it for misconduct, actions by the court such as making adverse findings as to the credibility of a witness or including critical language in a court opinion regarding the conduct of a third party do not give nonparties the right to appeal either from the ultimate judgment in the case or from the particular court statement or finding that they find objectionable”; “we conclude that the finding Mr. Teschner seeks to appeal is not a final decision within the meaning of 28 U.S.C. § 1295(a)(1), and that Mr. Teschner does not have standing to appeal from the final judgment in the lawsuit between Nisus and Perma-Chink. We therefore dismiss the appeal from the district court’s inequitable conduct decision, and we affirm the denial of Mr. Teschner’s motion to intervene”

Caritas Technologies, Inc. v. Comcast Corporation, et al. (08/17/2007, non-precedential): affirmed appeal from the U.S. District Court for the Eastern District of Texas (case no. 2:05-CV-339); no reasoning provided within the opinion

POSTX Corporation, et al. v. Secure Data in Motion, Inc (doing business as Sigaba) (08/17/2007, non-precedential): affirmed appeal from the U.S. District Court for the Northern District of California (case nos. 02-CV-04483 and 03-CV-00521); no reasoning provided within the opinion

September 07, 2007

The Federal Trade Commission (“FTC”) announced on Thursday that a $60 million court judgment was assessed against the Patent and Trademark Institute (“PTI”), an invention promotion company, for defrauding approximately 17,000 consumers. According to the article (link below), PTI “promised consumers it would screen their ideas before taking fees,” but that “nearly all ideas made it through the screening process.” PTI, based in Garden City, New York, was ordered by the FTC in 1998 to alert future PTI customers that no prior customer has ever made the amount of money back that he or she has paid to PTI for their services. The $60M judgment, ordered by the U.S. District Court for the Eastern District of Virginia based upon violations of the 1998 order, resulted in part from a large number of consumer protection complaints received since the 1998 order. According to the FTC Press Release (link below), “For a fee of $5,000 to $45,000, PTI’s clients were offered legal protection and assistance to obtain commercial licenses for their inventions. They also were told that PTI would help them earn substantial royalties from their inventions, but PTI did not help consumers license their inventions, and clients did not earn royalties.” Several other companies operated through PTI, including Azure Communications Inc., London Communications Inc. and United Licensing Corp, International Patent Advisors Inc., Datatech Consulting Inc., International Marketing Inc. and Unicorp Consulting Inc., were all held in contempt by the Virginia court. The FTC has set up a phone number (available in the FTC link below) for consumers to call if they believe they have been defrauded by PTI. Article: LINK
FTC Press Release: LINK

September 05, 2007

The USPTO recently announced that it and the United Kingdom Intellectual Property Office ("UK IPO") will now be "accepting" patent applications for fast-track examination. According to the USPTO press release (link below), "[t]he Patent Prosecution Highway will leverage fast-track patent examination in both offices to allow applicants in both countries to obtain corresponding patents faster and more efficiently" and "[i]t also will permit each office to benefit from work previously done by the other office, in turn reducing examination workload and improving patent quality." This joint effort (as part of the pilot Patent Prosecution Highway effort) will allow "an applicant receiving a ruling from either the UK IPO or the USPTO that at least one claim in an application is patentable" to request that the other patent office "fast track the examination of corresponding claims in corresponding applications." This trial period will run for one year (until September 4, 2008). The requirements for participation in the USPTO / UK IPO program can be found at the link below.

USPTO Press Release: LINK
Corresponding UK IPO Press Release: LINK
UK Intellectual Property Office: LINK
Participation Requirements: LINK

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The DDIP Author

Mark Reichel
Reichel IP LLC

I am a patent attorney with Reichel IP LLC, where I concentrate my practice on patent drafting and prosecution, trademarks, and general intellectual property matters. I currently focus on the preparation and prosecution of medical device and other life sciences patent applications, and being actively involved in a number of local not-for-profit organizations.

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