Opinions — Tuesday, March 31, 2026

The Seventh Circuit vacated a default judgment entered after a bench proceeding and remanded with instructions to dismiss for lack of personal jurisdiction in this Schedule A trademark infringement case brought under Lanham Act §§ 32 and 43(a). Plaintiff Yinnv Liu, holder of a registered trademark consisting of three stylized Chinese characters, sued hundreds of China-based online vendors (including Monthly and various Joybuy entities) operating e-commerce stores on platforms like Walmart.com for trademark infringement, counterfeiting, and false designation of origin. The district court entered default judgment after defendants failed to appear, finding personal jurisdiction based on defendants' operation of stores accessible in Illinois, offers to ship to Illinois, and purported sales to Illinois residents. When defendants later moved under Rule 60(b) to vacate for lack of jurisdiction, the district court denied the motion, reasoning that defendants offered no factual basis to revisit its prior jurisdictional findings. The Seventh Circuit held that the district court clearly erred in finding Illinois sales had occurred and therefore legally erred in concluding it possessed specific personal jurisdiction over the foreign defendants.

The court's jurisdictional analysis matters because it clarifies the quantum of forum-state contact required in Schedule A litigation involving foreign online merchants. While the court acknowledged that operation of an online store accessible in the forum state combined with completed sales in that forum suffices for specific personal jurisdiction under NBA Properties, Inc. v. HANWJH, 46 F.4th 614 (7th Cir. 2022), it reaffirmed the principle from Curry v. Revolution Laboratories, LLC, 949 F.3d 385 (7th Cir. 2020), that merely operating even a "highly interactive" website accessible from and offering shipping to the forum state cannot alone establish purposeful availment. The record contained only screenshots showing a checkout page with a Chicago address and estimated total—demonstrating the possibility of Illinois purchases—but no evidence of completed transactions. Even Liu's own TRO motion characterized the evidence as showing products "were offered for sale" to Illinois residents, not that actual sales occurred. Without completed sales, the remaining contacts (website accessibility and shipping offers) proved insufficient to satisfy Due Process's purposeful-availment requirement for specific jurisdiction.

The Federal Circuit affirmed the Northern District of California's grant of judgment on the pleadings that claim 1 of 10Tales's U.S. Patent No. 8,856,030—directed to a system for presenting personalized digital media content based on user social network information—was invalid under 35 U.S.C. § 101. The court applied the two-step Alice framework and concluded the claim was directed to the abstract idea of presenting personalized content based on user information, and that the claim lacked an inventive concept sufficient to render it patent eligible.

The court's analysis at Alice step one turned on the principle that claims written to achieve functional results without specifying "how" those results are achieved at some level of concreteness claim only abstract ideas. The court found claim 1 recited generic functions—retrieving social network data, selecting assets, and substituting content upon a "personalization opportunity"—without specifying implementation details. At step two, the court rejected 10Tales's argument that retrieving information from external social networks constituted an inventive concept, emphasizing that novelty under § 102 does not satisfy the distinct § 101 inquiry and that a "new abstract idea is still an abstract idea." The court likewise dismissed the "rule based substitution" limitation as nonspecific after 10Tales failed to argue for a narrow construction at the claim construction stage.

Tesla, Inc. v. Charge Fusion Technologies, LLC concerns the Federal Circuit's review of a Patent Trial and Appeal Board decision finding Tesla failed to prove claims of U.S. Patent No. 10,819,135 invalid as obvious. The patent relates to electric vehicle charging systems that intelligently operate climate control mechanisms while the vehicle is parked. The court affirmed in part, reversed in part, vacated in part, and remanded, holding that the Board improperly construed a limitation in independent claim 1 but correctly construed similar limitations in independent claims 8 and 14.

The court's analysis turned on whether claim language requiring operation of climate control "until" a predetermined battery level is reached necessarily means the operating instructions must "take into consideration" or "take into account" the battery level. The court held the Board erred as to claim 1 because neither the claim language nor the specification supported reading such a requirement into the "until" language, which is simply silent as to what happens after the battery threshold. By contrast, claims 8 and 14 expressly recited "a threshold amount of time" and required either a determination that the mode of operation cannot be maintained beyond that threshold time or a definition of minimum battery charge required to maintain temperature for that threshold—language the court held necessarily requires determining time available for climate control based on battery level, supported by both claim language and specification disclosures about time-based notifications.

The Federal Circuit affirmed two final written decisions by the Patent Trial and Appeal Board (PTAB) holding all challenged claims of Manufacturing Resources International's U.S. Patent Nos. 8,854,595 and 9,173,322 unpatentable as obvious. The patents concern cooling systems for electronic displays that use a "constricted convection plate" to direct airflow across the back of a hot display surface. Samsung had successfully petitioned for inter partes review, arguing that prior art references—Kim and Na—disclosed the claimed constricted convection plate, and the Board agreed, also finding MRI's objective-indicia evidence of nonobviousness entitled to little weight.

The court's analysis turned on whether substantial evidence supported the Board's findings that both prior art references disclosed the claimed constricted convection plate. The court upheld the Board's finding that Na's express teaching that through-holes "may be formed only in the first to fourth sidewalls" disclosed a bottom plate without holes, rejecting MRI's argument that Na's objective of maximizing airflow precluded such an embodiment. The court also sustained the Board's determination that Kim's disclosure of a shield cover that "efficiently guided" airflow taught constricting airflow, finding the concepts sufficiently related and noting MRI cited no rebuttal evidence. On claim construction, the court rejected MRI's attempt to import specification limitations requiring that "access apertures" provide hardware access and be pluggable, holding the specification merely provided examples without mandating those features.