Opinions — Tuesday, July 7, 2026

The Sixth Circuit affirmed summary judgment for MillerKnoll on all claims, including trademark infringement under § 43(a) of the Lanham Act and common law infringement claims concerning the Bubble Lamp configuration marks and the "BUBBLE LAMP" wordmark. Plaintiffs—the son and estate of mid-century furniture designer George Nelson—challenged MillerKnoll's ownership and use of three Bubble Lamp trademarks that MillerKnoll acquired from a third-party infringer, Modernica, after the George Nelson Foundation sued Modernica and settled. The court held that a 2006 Royalty Agreement between Nelson's widow and MillerKnoll (then Herman Miller), as amended by a 2015 Addendum, unambiguously authorized MillerKnoll to own and use the Bubble Lamp IP. Applying Michigan contract law, the court concluded that although the agreements used the defined term "Licensed Products," the plain language of the contracts—particularly provisions granting MillerKnoll "exclusive right, title, and interest to all inventions and designs" and "all . . . other materials pertaining to any product"—conferred ownership rights, not merely a license. Because plaintiffs authorized the conduct they challenged, the court ruled they could not sustain infringement claims and also granted summary judgment on plaintiffs' fraud, unjust enrichment, and cancellation claims.

The decision matters primarily for its holding that authorization defeats a § 43(a)(1)(A) unregistered trademark infringement claim even though the statute's text, unlike § 32's registered-mark provision, does not explicitly require use "without consent." The court imported the consent requirement from § 32 based on the parallel structure of the two provisions and reasoned that where a trademark holder authorizes use of a mark, no likelihood of confusion can exist and thus no Lanham Act violation occurs, citing Segal v. Geisha NYC LLC, 517 F.3d 501 (7th Cir. 2008). The court also addressed what rights transfer when parties use ownership-like language ("exclusive right, title, and interest to all inventions and designs") in a royalty agreement labeled as covering "Licensed Products," holding that configuration trademarks protecting product design necessarily follow assignment of the underlying design rights and that wordmarks are "materials pertaining to" the products and thus within the grant's scope. The court rejected plaintiff's argument that his subjective belief he was negotiating only a license controlled, applying Michigan law that unilateral subjective intent cannot override unambiguous contract terms.

In Hanwha Solutions Corp. v. Maxeon Solar PTE. Ltd., the Federal Circuit dismissed the appeal from a Patent Trial and Appeal Board decision in IPR2024-01203 pursuant to a joint stipulation under Federal Rule of Appellate Procedure 42(b), with each side bearing its own costs.

In Pictiva Displays International Ltd. v. Samsung Display Co., Ltd., the Federal Circuit dismissed the appeal from a Patent Trial and Appeal Board decision in IPR2024-01093 pursuant to a joint stipulation under Federal Rule of Appellate Procedure 42(b), with each side bearing its own costs.

In re Lambeth Magnetic Structures, LLC involves a petition for writ of mandamus seeking to vacate a district court order staying patent infringement litigation pending resolution of ex parte reexamination proceedings. The Federal Circuit denied the petition, holding that Lambeth failed to demonstrate a clear and indisputable right to relief under the Cheney standard and that the district court acted within its broad discretion in balancing the Murata factors, including the potential for simplification against prejudice from witness unavailability and finding that Seagate's post-remand request for reexamination was not an improper tactical maneuver.

The Federal Circuit affirmed summary judgment that claims of Dental Monitoring's U.S. Patents No. 11,049,248 and 10,755,409 are invalid under 35 U.S.C. § 101 as directed to ineligible subject matter. The patents relate to methods for analyzing dental arch images using a "deep learning device"—specifically, assessing orthodontic aligner fit (the '248 patent) and acquiring and evaluating image quality (the '409 patent). The district court had structured the case as a "patent showdown," requiring each party to select one claim for cross-motions for summary judgment, with the parties stipulating that the court's ruling on those claims would apply to related dependent and independent claims.

Applying Alice Corp. v. CLS Bank Int'l, the court held at step one that the claims were directed to the abstract idea of collecting, analyzing, and displaying image information, applying machine learning to a new field without providing a specific technological solution. The court rejected Dental Monitoring's argument that quantitative assessment of aligner-tooth separation constituted a technological advance, noting the claim language required no such precision beyond what an orthodontist could already determine. At step two, the court found no inventive concept because the "deep learning device" was admittedly generic—the patents themselves identified it as selectable from a list of well-known neural networks—and training the device on specific dental images was merely "incident to the very nature of machine learning" under Recentive Analytics, Inc. v. Fox Corp.